Privacy Notice

Welcome to the MyNucala mobile app!  We refer to this mobile app throughout this Privacy Notice as “MyNucala App", the “mobile app” or the “app”.  This mobile app was developed and designed by Curatio Networks Inc. (“Curatio”) with input and advice from GlaxoSmithKline Inc. (“GSK” or “Sponsor”), who sponsors this app and is the manufacturer of Nucala. 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 MyNucala.  If you have any questions, please contact Curatio’s Privacy Officer at privacy@curatio.me.

1. Who makes the MyNucala App? 

Curatio Networks Inc. makes the MyNucala App and decides what personal information to collect, how the app will work, and how to support members. GSK is the Sponsor of the app and provides input and advice to Curatio on the MyNucala App design. We refer to GSK as the “Sponsor”. Curatio does not share personal information from the MyNucala App with third parties, including the Sponsor, without the explicit consent of members or unless required by law, for example, in the case of an adverse event (see #5 below). 

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 the MyNucala App collect?

Required:

• Account information - user name, email address

• Basic information - gender, month and year of birth, location (country, state/region)

• Personal health information - Drug Identification Number (“DIN”) and when you started the medication, the diagnosis for which Nucala has been prescribed 

Optional:

• Location (city)

• User story

• Interests

• Height, weight

• Medications

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

• Symptoms (including date of onset)

• Non-pharmacological (non-medical) interventions for symptom management

• Personal notes about side effects and medications

• Personal appointment tracking

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 MyNucala App. 

Curatio uses your personal information to:

• create your MyNucala App 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;

• create My Health Report;

• deliver curated content to you in the app;

• create anonymous data about members and what members do in the MyNucala App;

• contact you with updates and information about the MyNucala App; 

• understand how you use the MyNucala 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 MyNucala App.  

• If you choose to use certain features, 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 Sponsor’s patient community and have been referred to the MyNucala App, the Sponsor will not have access to or receive any personal information from your MyNucala App profile or activities in the app.

Curatio uses information about you and what you do in the MyNucala App to create data that does not identify you or link you to your personal information. This anonymous data is used to understand the needs of the MyNucala App community and Curatio shares it with the Sponsor. 

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;     

• An Adverse Event is being reported (see #5 below);

• 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 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 MyNucala App requires them to see it. 

Curatio uses third parties to help deliver the MyNucala App to you. These third parties can see your personal information. They are only allowed to use your personal information to deliver the MyNucala 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 MyNucala 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 your health journey or your health 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 allowed in the MyNucala App.

The MyNucala App pulls information from your trackers to create My Health Report. You can review your report in the app and then create a pdf.

• By default, My Health Report is not shared with anyone.

• To create a pdf version, you will be asked if you would like to provide your name, which would be kept locally on your device and not sent to Curatio’s database.

• Your name will be added to the pdf, if you provide it.

• You can choose to print and share the report using email or SMS.

• Neither Curatio nor the Sponsor assume liability for how you use your My Health Report (pdf) or who you share it with.
  

5. Adverse Events

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

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

The Sponsor is legally required to report adverse drug events to Health Canada and to monitor Product complaints. If a Community Manager confirms an Adverse Event, the Community Manager will report it to GSK’s Patient Safety Team. The report will only include your username and adverse event details. GSK’s Patient Safety Team may contact you via the Community Manager to obtain your consent for the collection of additional information as required to fulfill these obligations.   

For more information on Adverse Events, please visit GSK Canada Inc.’s Adverse Event reporting webpage here.

6. How long do we keep your personal information? 

Curatio will keep your personal information while you are using the MyNucala App. If you don’t use the MyNucala App for one (1) year, Curatio will remove your account and personal information from the MyNucala App.

You can also go into settings to cancel your account and ask Curatio to remove your personal information from the MyNucala 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 MyNucala App for record 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 MyNucala App for Curatio to remove personal information from the copies. 

7. How do we protect your personal information?

Curatio follows Canadian privacy laws, and other privacy and data protection laws where required. 

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 MyNucala App promise to protect your personal information. They may use personal information only under Curatio’s instructions to deliver the MyNucala App.
  

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

You have the right to access your personal information in the MyNucala 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.

You can ask Curatio for a copy of the personal information you have provided to us, which we will prepare for you in a way that is usable if you want to move your personal information to other services.

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

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

Yes, Curatio’s computers use automated methods (a set of rules) to automatically assign you to a group in the MyNucala 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 automated methods (a set of rules) to look at your personal information and match you to other members of the MyNucala App that aren’t in your group. The MyNucala App then suggests these friends to you in the app. You decide if you want to invite a suggested friend into your circle. 

The MyNucala 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 journey and trackers in the app is not used for matchmaking in the app.

You decide how much personal information to give to the MyNucala 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 automated methods (a set of rules) in the MyNucala 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 MyNucala App for children? 

By design, the MyNucala App does not collect personal information from individuals who are under eighteen (18) years old.

11. Where is your personal information kept? 

Your personal information may be accessible by service providers (e.g., processors routing information) that may be located outside of Canada, including in the United States. However, your personal information will be stored on servers in Quebec 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 MyNucala App deals with your personal information? 

You can tell Curatio’s Privacy Officer at privacy@curatio.me if you are worried about the MyNucala App and your personal information. 

If telling Curatio’s Privacy Officer doesn’t help, you can tell the Privacy Commissioner or regulator in your province or the Office of the Privacy Commissioner of Canada.     

Privacy Commissioner of Canada