Last Updated: 04.09.2019
What is personal data?
What type of Personal Data do we collect?
As you use our Platform, we collect certain data about you and your use of the Platform. The data we collect falls into three different categories: (a) information you provide us; (b) information we collect from you automatically when you use our Platform; and (c) information we collect from our partners and other sources.
Information you provide
Tonic App may collect information you provide directly to Tonic App and/or its service providers (the “Service Providers”) when you use our Platform. This includes, but is not limited to:
a) Personal Data you provide when you create an account (the “Account”) or register on the Platform. When you create an Account, we ask for Personal Data, which may include your first and last name, birthdate, email, phone number, medical specialty, medical license, country of practice, professional background and education institution. Once you have completed the registration process, you may at any time provide additional information to your profile, including professional roles or positions, subspecialty, city of practice, practice website, education and training details, research interests, publications, scientific societies you belong to, list of congresses you usually attend, medical and research contacts and collaborators, and list of keywords best describing you and your career, for prospective professional connections. Providing additional information is entirely optional, but enables you to better identify yourself professionally and find new opportunities in the Platform to build and leverage your professional network. The information that is publicly available or you voluntarily provide will be published in your profile, except your birthdate, which is accessible to other users browsing the Tonic App mobile application.
b) Personal Data you provide when you update your account.
c) Personal Data you provide when you participate in a survey or promotion.
Information collected automatically
Tonic App, its Service Providers, and/or Tonic App’s partners or affiliates may automatically collect certain information about you when you access or use the Platform (“Usage Data”). Usage Data may include IP address, device identifier, browser type, operating system, information about your use of the Platform, and data regarding network connected hardware (e.g., computer or mobile device).
The methods that may be used on the Platform to collect Usage Data include:
a) Log Information: Log information is data about your use of the Platform, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
b) Information Collected by Tracking Technologies: Location-identifying technologies, device tokens, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Platform.
i) Location-identifying Technologies: GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting content based on your location.
ii) Device Tokens: A device token is a unique identifier issued by the operating system of your mobile device. You may sign up to receive “push notification” messages through the Platform. To ensure messages reach the correct devices, we rely on a device token unique to your mobile device. While we may be able to access a list of the tokens, the mobile app and tokens do not reveal your identity, unique device ID, or contact information to us.
Some information about your use of the Platform may be collected using Tracking Technologies across time and services, and used by Tonic App’s and third parties for delivering the Platform.
Information Tonic App collects from partners and other sources
We may collect Personal Data that you have provided to our subsidiaries, affiliates, business partners and/or businesses related to Tonic App for purposes set out below. Tonic App is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices. As a general rule, Tonic App collects Personal Data directly from you. If third parties hold information Tonic App requires, we will endeavor to ensure the information has been collected with your consent.
Specifically, we may collect and use Personal Data that is aggregated and anonymised (the “Analytic Information”) from our subsidiaries, affiliates, business partners and/or businesses related to Tonic App, for various business purposes, including, without limitation, enabling us to provide the Platform. This Analytic Information, because it is aggregated and anonymised, is no longer Personal Data as it cannot be used, alone or in conjunction with other information, to identify an individual. We may use this Analytic Information in a variety of ways, including to help analyze site traffic, understand users’ needs and trends, and to improve our products and services. We may use this information by itself or aggregate it with information we have obtained from others.
Further, we may use, transfer, lease, sell or otherwise commercialise Analytic Information for any and all purposes without notice or obligation to you, provided that the Analytic Information does not indicate your identity and cannot be used, alone or in conjunction with other information, to determine your identity. You will not have any rights arising from the creation, collection or use of the Analytic Information.
Why do we collect your Personal Data?
We collect Personal Data for purposes related to managing and developing our businesses and operations, including but not limited to:
a) Establishing, managing and terminating business relations with you.
b) Reviewing the products and services that we provide to you, or that you provide to us.
c) Communicating and sending curated healthcare related information of interest to you, including newsletters, alerts, notifications.
d) Informing you of our products and services other than those that you have specifically requested.
e) Tracking and analysing trends and patterns related to our businesses and operations for market research related purposes.
f) Providing you with the Platform.
g) Creating aggregated information or Analytic Information that does not individually identify you.
h) Complying with applicable law or regulatory requirements.
i) And any other reasonable purpose to which you consent.
In addition to the foregoing, we may also use and disclose your Personal Data for other purposes, which we will disclose before the time of collection.
How will we use your Personal Data?
We may also use your Personal Data to investigate security breaches or cooperate with government authorities pursuant to a legal matter.
Tonic App is committed to complying with European Anti-Spam Legislations. In the case of personal contact information provided in conjunction with any newsletter or other marketing initiatives, you can withdraw your consent to receiving those communications and unsubscribe from any Tonic App subscriptions at any time by contacting our Data Protection Officer (“DPO”) using the contact information provided below. In addition, commercial electronic communications sent by Tonic App to which you have subscribed will further contain an unsubscribe mechanism.
If you choose to invite a colleague to use the Platform through our Invite Colleagues function, we will collect your name, phone number and email address, as well as the name, phone number and email address of the recipient. We will automatically send your colleague a one-time email and text inviting him or her to use the Platform. We do not use the names or email addresses submitted in these circumstances for any other purpose without the consent of you or the email recipient to do so. To fulfill our obligations under European Anti-Spam legislations, please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the message from you.
We reserve the right to send you transactional or informational emails such as customer service communications in connection with the products you have registered to use or changes to the website or policies.
How is your Personal Data disclosed?
In addition to the purposes set out above, we may disclose Personal Data for purposes related to:
a) Managing and developing Tonic App’s businesses and operations.
b) Managing your Account.
c) Providing you with the Platform.
d) Creating and maintaining a responsible business relationship with you.
e) Creating aggregated information or Analytic Information that does not individually identify you.
f) Communicating with you on topics related to your Account, Platform, and other matters related to Tonic App.
g) Informing you of our products and services other than those that you have specifically requested.
h) Tracking and analysing trends and patterns related to our businesses and operations for market research related purposes.
i) Interacting with you on social media.
j) And other purposes identified when the Personal Data is collected, or as permitted or required by law.
Personal Data is disclosed to third parties for purposes set out above, including, but not limited to:
b) Third party service providers, affiliates and business associates including an organisation or individual retained by Tonic App to perform functions on its behalf.
c) Any third party, where you have provided your consent for such disclosure or where disclosure is required or permitted by law.
On rare occasions, we may use or disclose your Personal Data without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
Tonic App may share or sell aggregated, de-identified data that does not identify you with partners and the public in a variety of ways. When we provide this information, we ensure that the data does not identify you and cannot be associated back to you.
Notification Respecting Service Providers Internationally
To ask any questions or to obtain written information about Tonic App’s policies and practices regarding those service providers, you may write to our DPO at the address listed below in the “How to contact us?” section.
How does Tonic App obtain consent?
We may collect, use or disclose your Personal Data without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the office of our DPO using the contact information set out below. In some circumstances, a change or withdrawal of consent may limit our ability to provide products or services to you or acquire products or services from you.
What are my tracking options?
With respect to Tonic App’s mobile apps, you can stop all collection of data generated by use of the app by uninstalling the app. You may also be able to exercise specific privacy choices, such as enabling or disabling push notifications, by adjusting the permissions in your mobile device.
How does Tonic App safeguard Personal Data?
Tonic App will endeavor to safeguard Personal Data using methods that are appropriate to the sensitivity of the information. Namely, Tonic App is ISO-27001 certified, the international standard for managing risks to the security of information held by organisations. Specifically, Tonic App takes the following steps to safeguard any Personal Data that it collects:
a) Protecting the confidentiality of all Personal Data when doing business internally or externally with other organisations.
b) And protecting all Personal Data with appropriate and effective security safeguards, including physical, administrative, and technology safeguards, against such risks as loss or theft, unauthorised access, disclosure, copying, use or destruction, regardless of the format in which it is held.
How does Tonic App store Personal Data?
Tonic App collects and stores your information on secure, European Union servers. For our overseas visitors, your data may be collected and stored on secure, offsite servers that meet the laws and policies of your country.
How to correct inaccurate Personal Data?
It is important that any Personal Data Tonic App holds about you is accurate and current. Tonic App requires you to keep us informed of changes to any Personal Data. You can correct any inaccuracies by accessing and modifying the information provided in your Account.
How does Tonic App retain Personal Data?
Tonic App retains Personal Data in accordance with its legal or business practices. We retain your Personal Data up to one year after you cease to be a Tonic App active Platform user. You will be considered an inactive user after one year with no activity in the Platform, starting from the date of your last access. Once the Personal Data is no longer required to fulfill the purpose for which it was collected and no longer required or permitted to be retained for legal or business purposes, it is securely destroyed or made anonymous.
How to access your Personal Data?
Any data that you provide to Tonic App can be accessed and modified from your Account. If you remove data from your profile, it will no longer appear to you or others who use the Platform. Backups of that data will remain in association with your Account and in our archive servers until deleted in accordance with our data retention schedule.
You can also ask to see the Personal Data that we hold about you. If you want to review, verify or correct your Personal Data, please contact our DPO using the contact information set out below. Please note that any such communications must be in writing.
When making an access request, we may require specific information from you to confirm your identity and right to access, as well as to search for, and provide you with, the Personal Data that we hold about you. If you need help in preparing your request, please contact our DPO.
For any personal data shared with your consent you can ask Tonic App to provide you with a copy of such data in a commonly used and machine-readable format. You can also request of Tonic App, if technically feasible, to send this information to other data processors.
Tonic App may not be able to provide you with access to your Personal Data, in situations where such refusal is permitted or required by applicable law or regulatory requirements. Tonic App will inform you of the reasons why, subject to any legal or regulatory restrictions, access has been denied.
User-Provided Case Information
When you use the Tonic App mobile application, you may upload images and videos, create image captions, use tags, share images and videos and exchange messages with other users or group of users.
All user-provided case information that you generate in the Tonic App mobile application must comply with local, national, provincial, state, and federal privacy legislation and best practices. Identifying information must be removed from any uploaded images or videos and should not be included in any captions or messages.
We will store your uploaded images, videos, image captions, date created, and tags used. Tonic App mobile application stores only encrypted images or videos, not the original unedited images/videos. We do not store IP addresses, time or location information relating to images or videos uploaded by users.
We will also store the date your account was created, the mobile application version, and the last login date.
As a user, you have certain obligations toward the other users with whom you will be communicating. Certain of these obligations are imposed by applicable law and regulations, and others have become commonplace in user-friendly communities of like-minded members, such as the Tonic App mobile application:
You must not upload or otherwise disseminate any information which may be deemed to be injurious, defamatory, violent, offensive, racist, sexist or xenophobic, or which may otherwise violate the purpose and spirit of the Tonic App professional mobile application and its community of users.
You must not provide information to Tonic App and/or other users which you believe might be injurious or detrimental to your person, professional or social status.
You must not use our free peer-to-peer invite and secure communications system for commercial use. While we do allow selected client outreach for partner information, market research, expert witness and career opportunities, these messages have a distinct format to protect our users. Those found soliciting, scamming, or spamming other members will be removed or suspended from the network at our sole discretion.
Any violation of these guidelines may lead to the restriction, suspension or termination of your Account by Tonic App, as we take these principles seriously and consider them to be the basis on which our users adhere to the Platform.
How do you deactivate your Account?
You can deactivate your Account by contacting us at email@example.com. When you do, data that can identify you will be removed from the Account, including, but not limited to, your email, name, birthdate and photo. Backup copies of this data will be removed from our servers based upon an automated schedule, which means it may persist in our archive for at most thirty (30) days. Tonic App may continue to use your de-identified data.
How does Tonic App handle complaints?
How does Tonic App handle children’s privacy?
The Service is intended for healthcare professionals and not directed to individuals of less than 18 years of age. If you are a parent or guardian and believe we may have collected information about a child, please contact us as described in the “How to contact us?” section, below.
How to contact us?
DPO: Daniela Seixas
Address: Alameda Eça de Queirós, 350 2º andar habitação 1, 4200-272 Porto, Portugal
Telephone Number: +351 223162973
Email Address: firstname.lastname@example.org
Portuguese Data Protection Supervisor: Comissão Nacional de Proteção de Dados
Address: Rua de São Bento n.º 148-3º 1200-821 Lisboa, Portugal
Telephone Number: +351 213928400
Email Address: email@example.com
Last Amended: 04.09.2019