Curatio Freedom Friend Mobile App

Privacy Notice 

August 30, 2022

Welcome to the Freedom Friend app! This mobile app was developed and designed by Curatio Networks with input and advice from the app sponsor Sanofi Canada Inc. An important feature of this app is the way in which your privacy is maintained. This notice explains what happens to your personal information when you use the Freedom Friend app. If you have any questions, please contact Curatio’s Privacy Officer at privacy@curatio.me

1. Who makes The Freedom Friend app? 

Curatio Networks Inc. makes the Freedom Friend app and decides what personal information to collect, how the app will work, and how to support members. Sanofi sponsors the app and provides input and advice to Curatio on its design. Curatio does not share personal information from the Freedom Friend app with third parties, including Sanofi, without the explicit consent of members.

Curatio Networks Inc. 

1200 – 555 West Hastings Street
Vancouver, B.C.
V6B 1M1
Toll free 1-855-888-2031
International +1 778 985 7907
info@curatio.me 

Curatio Privacy Officer
privacy@curatio.me

2. What kind of personal information does Freedom Friend collect?

When you join the Freedom Friend App, Curatio will collect personal information about you from Innomar Strategies      Inc., the provider of the Freedom Friend patient support program (“PSP”). You will need to provide your PSP ID number and your month and year of birth to create your Freedom Friend App account. We will confirm your PSP enrollment by checking what you’ve entered against Innomar Strategies’s database.

Once enrollment is confirmed, Innomar Strategies will send Curatio the following information to add to your Freedom Friend App profile: 

• Status

• Province/territory of residence

• Gender

• PSP enrolment start date

• Indication

• Opted-out date

• Therapy start date

Optional:

• GPS location 

• User story

• Interests

• Height, weight

• Medications

• User activity - posts, comments, likes, behavioural activity from use of the app

• Wellness information – stress, energy, sleep quality, mood, exercise

  
  

3. What do we do with your personal information?

Curatio uses your personal information when you give your consent (say it’s okay) and sign up for Freedom Friend.

Curatio uses your personal information to:

• create your Freedom Friend account;

• group you with other members at a similar stage in the health journey;

• match you with other members; 

• let you communicate with other members;

• deliver curated content to you in the app;

• create anonymous data about members and what members do in Freedom Friend;

• contact you with updates and information about the Freedom Friend app; 

• understand how you use the Freedom Friend app so we can improve it; 

• help you when you need it; and

• reply when you have questions or want to tell us something you like or don’t like about The Freedom Friend app. 

If you choose to use the health trackers and medication reminders in the Health Tools section of the app we will use your personal information to help you:

• keep track of and review your health events; and

• enable you to keep track of your medications.

Curatio knows who you are from the personal information you enter. If you are participating in a Sanofi patient community and have been referred to the Freedom Friend app, Sanofi will not have access to or receive any personal information from your Freedom Friend app profile or about your activities in the app.

Curatio uses information about you and what you do in the Freedom Friend app to create data that does not identify you or link you to your personal information. We may also combine your personal information from the app with personal information from third parties where you have given your consent for those third parties to disclose your personal information to Curatio. This anonymous data is used to understand the needs of the Freedom Friend app community. 

Curatio does not sell, rent, or share your personal information. 

Curatio may make your personal information known to third parties if:

• The law says Curatio has to reveal it;

• Curatio believes it is necessary to protect your safety, the safety of other members, or the public; or

• Curatio has to reveal your personal information to protect and defend our rights or property.

4. Who can see your personal information? 

Only certain technical Curatio employees will be able to see your personal information. They will see it only if they need to support you or if their work on the Freedom Friend app requires them to see it. 

Curatio uses other companies to help deliver The Freedom Friend app to you. These other companies can see your personal information. They are only allowed to use your personal information to deliver The Freedom Friend app.

You decide which personal information other members can see. You can go to the “settings” tab on the app and choose to show your basic information, basic health information, story and interests to other members.  

When you post something to the Freedom Friend app, you can choose to share it with the whole community, your circle, just one or two friends, or you can keep it private. In the same way, you can choose to share your wellness information (stress, energy, sleep quality and mood) with other members.

Other members cannot see your Health Tools or your medication trackers.

Curatio adds a Curatio Community Manager to your circle when you set up your account. Your Community Manager is there to support you. They can send private messages to the entire circle and can remove posts that are not good for the Freedom Friend community. Curatio uses sets of rules to identify profanity and inappropriate language in public posts and messages, which Community Managers can remove or follow up on.

5. Adverse Events

The law requires that pharmaceutical companies report unexpected or unwanted reactions to health products, known as “Adverse Events”, or side effects, that happen to someone using their medicine or treatments. 

The Freedom Friend® App is not intended to be used to report health concerns, adverse events or product technical complaints, or to ask technical or medical questions regarding products.  In all instances you should refer to your physician or pharmacist.

As a user of this app, if you provide information about an adverse experience or product technical complaint while using any of the products listed on this app, or any product of a company (including Sanofi), you understand that Curatio may have to report the information you provide to the company that supplies the product. To meet its regulatory requirements, the company may use the adverse event information you provided to submit reports to Health Canada and/or other relevant regulators. 

Curatio’s app uses a set of rules to identify potential Adverse Events from key words used in posts and messages in the Freedom Friend app. The app notifies Community Managers of potential Adverse Events so they can review the post or message. 

If Community Managers confirm an Adverse Event, they report it to Sanofi. The Community Manager provides enough information in the report so that Curatio can identify the member in the app. The Community Manager does not provide enough personal information to Sanofi so that they can identify the individual. 

If a Community Manager confirms an Adverse Event based on a post(s) or comment(s), the Community Manager will ask the member if they would like Sanofi to follow up. Only if the member requests a follow up, the Community Manager will provide the member’s contact information to Sanofi Canada’s Medical Information Office.   

If you request a follow up with Sanofi for an Adverse Event, Sanofi may be required to contact you and/or your healthcare professional for further information. You understand that in order to comply with the law, Sanofi may not be permitted to meet your request to amend or remove personal information you provided regarding an adverse experience while using any of Sanofi’s products. The process of adverse experiences may include and/or be managed by Sanofi, its affiliates or third-party service providers retained specifically for this sole purpose. The database is only accessible to employees, agents or authorized service providers for whom the information is needed in the performance of their pharmacovigilance duties. The collection, use, and disclosure of information related to Adverse Events may involve a transfer of the information to jurisdictions located outside your country of residence that may not have equivalent laws and rules regarding personal information. The reasonable contractual measures Sanofi may take to protect personal information while processed or handled by these third parties are subject to applicable foreign legal requirements. 

6. How long do we keep your personal information? 

Curatio will keep your personal information while you are using the Freedom Friend app. If you don’t use the Freedom Friend app for one (1) year, Curatio will remove your account and personal information from the Freedom Friend app’s active database.

You can also go into settings to cancel your account and ask Curatio to remove your personal information from the Freedom Friend app. Curatio removes your personal information by erasing it from the active database. It will take 60 days for Curatio to do this. 

Curatio regularly makes copies of the Freedom Friend app for safe keeping. Curatio keeps these copies in a safe place for five (5) years. It will take five (5) years from the time your personal information is removed from The Freedom Friend app for Curatio to remove personal information from these copies.

7. How do we protect your personal information?

Curatio follows Canadian privacy law, and other privacy and data protection law when fitting.  We use technical and organizational ways to protect your personal information.

Curatio:

• Puts your personal information into code (“encrypts it”) when moving and storing it. 

• Removes your personal information if there is no need to have your personal information. 

• Makes sure that only employees who need to see your personal information to do their jobs can see your personal information. 

• Makes companies helping to deliver the Freedom Friend app commit to protecting your personal information. They may use personal information only under Curatio’s instructions to deliver the Freedom Friend app.

8. What rights do you have to your personal information? 

You have the right to access your personal information in the Freedom Friend app. You can see and edit your personal information by opening the settings tab in the app. 

You can withdraw your consent for Curatio to keep using your information. You do this by canceling your account on the settings tab in the app.

You can ask Curatio to correct your personal information.

If you have questions about your rights and how to use them, please contact Curatio’s Privacy Officer.

9. Are computers used to make decisions based on your personal information? 

Yes, Curatio’s computers use a set of rules to automatically assign you to a group in the Freedom Friend app based on your answers to questions about how familiar you are with your disease and therapy. The group you are assigned to will include members at similar points in their health journeys so that you can support one another.

Curatio also uses a set of rules to look at your personal information and match you to other members of the Freedom Friend app that aren’t in your group. The Freedom Friend app then suggests these friends to you in the app. You decide if you want to invite a suggested friend into your circle. 

The Freedom Friend app will also suggest you as a friend to other members. The other members might send you an invite. You decide if you want to accept an invite into another member’s circle.

Personal information from your Health Tools and Medication Tracker is not used for matchmaking in the app.

You decide how much personal information to give to the Freedom Friend app. When you provide more information, your friend suggestions will be better matches for you and more likely to accept you into their circles. Remember, you can always update your profile with more information when you are ready.

Curatio uses a set of rules in The Freedom Friend app to identify Adverse Events (see 5 above). 

Curatio also uses a set of rules to identify profanity and inappropriate language in community posts and messages. 

10. Is The Freedom Friend app for children? 

By design, the Freedom Friend app does not collect personal information from individuals who are under thirteen (13) years old.

11. Where is your personal information kept? 

Your personal information will be stored in Canada.

Your Community Manager will be in Canada.  

Curatio employees who can see your personal information are in Canada.

12. Where can you go to complain about how The Freedom Friend app deals with your personal information? 

You can tell Curatio’s Privacy Officer if you are worried about the Freedom Friend app and your personal information. 

If telling Curatio’s Privacy Officer doesn’t help, you can tell the Privacy Commissioner of BC or the Canadian Privacy Commissioner:

Office of the Information and Privacy Commissioner of BC

Office of the Privacy Commissioner of Canada