Curatio MS One to One Mobile App

Privacy Notice (Canada) 
December 3, 2020

Welcome to the MS One to One app! Curatio Networks developed and designed this mobile app with input and advice from people living with Multiple Sclerosis. The app is sponsored by Sanofi Genzyme, a division of Sanofi-aventis. 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 MS One to One app. If you have any questions, please contact Curatio’s Privacy Officer at privacy@curatio.me

1. Who makes MS One to One?

   Curatio Networks Inc. makes the MS One to One app and decides what personal information to collect, how the app will work, and how to support members. Sanofi Genzyme Canada sponsors the app. Curatio does not share personal information from the MS One to One 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 MS One to One collect?

   MS One to One collects personal information, including personal health information.

   Required:

   • Program ID (provided by the MS One to One Patient support program)

   • Account information - user name, email address

   • Basic information - gender, age range, location (country, state/region)

   Optional:

   • User story

   • Medical Tags

   • User activity - posts, comments, likes, wellness tracking, survey participation, behavioural activity from use of the app

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 the MS One to One app. 

   Curatio uses your personal information to:

   • create your MS One to One app account;

   • match you with other members; 

   • let you communicate with other members;

   • create anonymous data about members and what members do in the MS One to One app ;

   • contact you with updates and information about the MS One to One program; 

   • understand how you use the MS One to One 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 MS One to One app.  

   Curatio knows who you are from the personal information you enter. Sanofi will know the Program ID you use to create your account but they will not have access to or receive any information about your MS One to One app profile or activities. 

   Curatio uses information about you and what you do in the MS One to One app to create data that doesn’t identify you or link you to your personal information. This anonymous data is used to understand the needs of the MS One to One 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 MS One to One app requires them to see it. 

   Curatio uses other companies to help deliver the MS One to One app to you. These other companies can see your personal information. They are only allowed to use your personal information to deliver the MS One to One 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, and story to other members.  

   When you post something to the MS One to One app, you can choose to share it with the whole community, your circle, just one or two friends, or you can keep it private. 

   Other members cannot see the personal information you enter in your Primary Diagnosis or Medical Tags on your profile.
   Curatio adds a Curatio Community Manager to your circle when you set up your account. Your Community Manager is there to support you. She or he can send private messages to the entire circle and can remove posts that are not good for the MS One to One app community.

5. Adverse Events

   The law says that pharmaceutical companies have to report surprise health events, called “Adverse Events”, that happen to someone using their medicine or treatments. 

   The Site 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,  you understand that Curatio may have to report the information you provide to the Company that supplies the product in order for the Company to meet its regulatory requirements. To do so, the Company may use the information you provided to submit reports to Health Canada and/or other relevant regulators in relation to an adverse experience with one of its products as may be required by the regulatory authority. The Company may be required to contact you and/or your healthcare professional for further information.  You understand that in order to comply with the law, we may not be permitted to meet your request to amend or remove Personal Information you provided to us or a third party regarding an adverse experience while using any products.

   Curatio uses a set of rules to identify potential Adverse Events from key words used in posts and messages in the MS One to One 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 using Curatio’s automated system. The report includes a screenshot of the message or post and includes enough information to identify you in the app. Community Managers remove any information in the post or message that will uniquely identify you to Sanofi, for example a phone number or an address.

   If a Community Manager reports an Adverse Event in one of your posts or messages, the app automatically sends you a notification in the app when the report is submitted to Sanofi. If you choose to contact Sanofi about the Adverse Event, they will decide how best to follow up with you. 

6. How long do we keep your personal information?

   Curatio will keep your personal information while you are using the MS One to One app. If you don’t use the MS One to One app for five (5) years, Curatio will remove your account and personal information from the MS One to One app.

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

   Curatio does not keep your Program ID (provided by Sanofi) once it has been validated.
   Curatio regularly makes copies of the MS One to One 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 MS One to One app for Curatio to remove personal information from the copies.

7. How your personal information is protected?

   Curatio follows Canadian privacy law, and other privacy and data protection law when fitting. 

   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 MS One to One app promise to protect your personal information. They may use personal information only under Curatio’s instructions to deliver the MS One to One app.

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

   You have the right to access your personal information in MS One to One. 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 personal information. You do this by cancelling 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, when you sign up for MS One to One, we get your consent for Curatio’s computers to use a  set of rules to look at your personal information and match you to other members. MS One to One then suggests these friends to you in the app. You decide if you want to invite a suggested friend into your circle. 

   MS One to One also suggests 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 user’s circle.

   You decide how much personal information to give to MS One to One. 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.

   MS One to One also uses a set of rules to identify Adverse Events (see 5 above).

10. Is MS One to One for children?

    By design, MS One to One does not collect personal information from members who are under eighteen (18) years old.

11. Is your personal information moved to a country other than your own?

    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 MS One to One deals with your personal information?

    You can tell Curatio’s Privacy Officer if you are worried about MS One to One 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