wegovycare® Mobile App

Privacy Notice

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Welcome to the wegovycare® mobile app! We refer to this mobile app throughout this Privacy Notice as “wegovycare® App", the “App”. This App was developed and designed by Medical Safety Systems Corporate Pty Ltd trading as “RxMx Australia/RxPx” (“RxPx”) with input and advice from Novo Nordisk Pharmaceuticals Limited New Zealand (“Novo Nordisk” or “Sponsor”), who sponsors this app and is the manufacturer and market authorisation holder of Wegovy® (semaglutide). 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 wegovycare® App. It describes how we collect, process, and share your personal information. If you have any questions, please contact RxPx’s Privacy Officer at privacy@rxpx.health.

RxPx may update this Privacy Notice if we change the way we handle personal information. We will post changes to this page with the date of the change. If we make meaningful changes to the handling of personal information, we will notify you in the App and/or via email.

1. Who makes the wegovycare® App?

RxPx makes the wegovycare® App and decides what personal information to collect, use, and share, how the App will work, and how to support members as described in this Privacy Notice. Novo Nordisk is the Sponsor of the App and provides input and advice to RxPx on the wegovycare® App design. RxPx does not share personal information from the wegovycare® App with third parties, including Novo Nordisk (unless required by law, such as safety reporting).

Medical Safety Systems Corporate Pty Ltd t/a RxPx
Post: Level 1/94 Mallett St
Camperdown NSW 2050
Tel: 02 8004 6877
contact@rxpx.health

RxPx Privacy Officer
privacy@rxpx.health

2. What kind of personal information does the wegovycare® App collect?

RxPx knows who you are from the personal information you enter when you sign up and use the wegovycare® App.

Required:

• Account information about the member – username, email address, password

• Basic information about the member – date of birth, age range, location (country, region)

• Health indication and comorbidities (based on criteria)

• Height

• Weight

• Biological sex (for patients aged between 12 and 17 only)

The required personal health information helps RxPx to provide services, including reminders, education and programme support from registered nurses, and relevant content.

Optional:

• Gender – the option “prefer not to answer” is presented during sign up

• Health tracking – weight, height, and sleep

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

• Personal messages, which may include personal health information

3. What do we do with personal information?

RxPx gets your consent when you sign up to use your personal information for the following purposes when you use the wegovycare® App:

• create the wegovycare® App account,

• deliver curated content in the App,

• create My Health Report,

• send you reminders,

• create anonymous data about members and patients and what members do in the wegovycare® App,

• provide you with registered nurses’ education and programme support (e.g. side effect management guidance and questions about the programme)
  Note: the nurses do not prescribe, diagnose, or modify your treatment. They may refer you to a healthcare professional for treatment decisions, diagnoses, dose changes, or clinical management,

• contact you with updates and information about the wegovycare® App,

• understand how you use the wegovycare® 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 wegovycare® App,

• If you choose to use certain features, we will use personal information to help you keep track of and review things like weight, dose escalation, and sleep quality

RxPx uses information provided by members, including personal information, and information about what members do in the wegovycare® App to create data that does not identify individuals or link individuals to personal information. RxPx uses this anonymous data to understand the needs of the wegovycare® App users. RxPx shares this anonymous information with Novo Nordisk, who uses it to understand how the App is used and make improvements based on the anonymous data.

RxPx does not sell, rent, or disclose personal information collected, used, or created in the wegovycare® App.

RxPx may make personal information known to third parties if:

• The law says RxPx must reveal it (for example, to meet safety and adverse event reporting obligations in which RxPx must share personal information strictly related to such comment with Novo Nordisk). Please see Section 4 for more information on adverse event reporting.

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

• RxPx must reveal personal information to protect and defend our rights or property.

4. Who can see personal information?

Only certain RxPx employees including the RxPx nurses will be able to see personal information you enter in the wegovycare® App. They will see it only if they need to support you or if their work on the wegovycare® App requires them to see it.

RxPx uses third parties to help deliver the wegovycare® App to you. These third parties may be able to see personal information. They are only allowed to use personal information to deliver the wegovycare® App.

RxPx uses these categories of companies in these locations to deliver the wegovycare® App:

• Data hosting, backups and file storage services – Australia

• Notification and messaging services – Australia

• Customer support and ticketing systems – Australia and United States

Other members cannot see the personal information you provide in the wegovycare® App.

The wegovycare® App pulls information from trackers to create My Health Report. You can review the 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 to provide a name, which is kept locally on your device and not sent to RxPx’s database. The name, if provided, will be added to the pdf.

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

• Neither RxPx nor the Sponsor assume liability for how you use the My Health Report pdf or with whom you share it.

Adverse Events

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

The Sponsor generally cannot see the personal information you provide in the wegovycare® App. However, if you report a side effect, product complaint, or safety concern to an RxPx nurse, the RxPx nurse may share information relevant to that report (including personal information) with the Sponsor and regulatory authorities to comply with pharmacovigilance obligations. The report will include your adverse event details and may include your personal information such as patient identification, initials, sex, year of birth or age, weight, height, and ethnicity.

5. How long do we keep personal information?

RxPx keeps your personal information while you are using the wegovycare® App. If you don’t use the wegovycare® App for one (1) year, RxPx will remove the account and any associated personal information from the wegovycare® App active database.

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

RxPx regularly makes copies of the wegovycare® App for record keeping. RxPx keeps these copies in a safe place for ten (10) years. It will take ten years from the end of the support program for RxPx to remove personal information from these backup copies.

If you remove personal information from your account or ask RxPx to remove it, you may no longer be able to use the wegovycare® App.

6. How do we protect personal information?

RxPx is subject to applicable privacy and data protection laws where we do business and where members are located. This includes New Zealand’s Privacy Act (2020).

We use technical and organizational ways to protect personal information.

RxPx:

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

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

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

• Gets companies helping to deliver the wegovycare® App to commit to protect personal information. These companies may use personal information only under RxPx’s instructions to deliver the wegovycare® App.

7. What are your personal information rights?

You have the right to access personal information you have provided in the wegovycare® App and to withdraw your consent. You can see and edit personal information by opening the settings tab in the App.

You have the right to ask RxPx to correct personal information, if you believe that it is inaccurate, outdated, or misleading.

You can cancel your account and ask RxPx to remove personal information from the wegovycare® App. You can do this by canceling your account on the settings tab in the App.

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

If you have questions about your rights, please contact RxPx’s Privacy Officer at privacy@rxpx.health.

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

Yes, RxPx uses automated methods (a set of rules) to deliver curated content that matches the personal information provided when you set up your wegovycare® App account.

9. Is the wegovycare® App for children?

Guardians are required to provide permission and documented consent for children and adolescents between the ages of 12 and 17 to create a wegovycare® App account.

10. Where is your personal information kept?

RxPx uses service providers in the United States to process and store personal information.

RxPx employees who can see your personal information are in Australia, Canada, and the US.

The email address you use for login will be stored locally on your phone. It is only collected for the purposes of providing our services and otherwise not collected into RxPx databases unless you sign up separately for our marketing communications.

RxPx takes reasonable steps to ensure transfers of personal information overseas are protected through contractual obligations and privacy safeguards that are comparable to those required under New Zealand privacy law.

If you want more information about RxPx’s service providers and where they are located, please contact our Privacy Officer at privacy@rxpx.health.

11. Where can you go to complain about how RxPx handles personal information?

You can tell RxPx’s Privacy Officer at privacy@rxpx.health if you are worried about the wegovycare® App and personal information.

If telling RxPx’s Privacy Officer doesn’t help, you can contact the New Zealand privacy regulator.

We may update this Privacy Notice if we change the way we handle personal information. We will post changes to this page with the date of the change. If we make meaningful changes to the handling of personal information, we will notify you in the App and/or via email.