Scope of this Privacy Notice
Biogen, Inc. of 225 Binney Street, Cambridge, MA 02142, USA (“Biogen”) has developed this MS Patient App to provide support to individuals living with Multiple Sclerosis (MS). This Privacy Notice describes what “personal information” we need to collect from you in the app, how we use it and why, and your rights in relation to this collection and use. You are under no obligation to provide personal information to us, but should you decide not to, you will not be able to use the app as it requires certain basic personal information to function, as described below. If you wish to continue, you will need to read the following information carefully and provide your consent by ticking the relevant tick box in the app.
Information we collect and how we use it
The different features of the app collect different types of personal information depending on your use of these features.
App registration. If you choose to use the app, you will need to create an account and user profile within the app. We will collect the following necessary personal information from you to do this: your name; e-mail address; password; country in which you live; the date you registered to use the app; and topics of interest to you regarding MS. We will then assign you with a unique app user registration number. If you choose to provide it, we may also collect the following personal information from you: gender; date of birth; month and year of MS diagnosis; and type of MS. We require this information to: (a) create and manage your account; (b) tailor your user experience and provide you with information that matches your personal profile and preferences; and (c) provide you with local technical and administrative support, where necessary.
MS journal.If you use the journal feature of the app, this allows you to have a full picture of your MS and will involve your recording health information concerning your MS (such as mood, symptoms, fitness and physical activity) and medical history (including whether/when you were diagnosed with MS, type of diagnosis, treatment and medication). The journal also allows you to manage your medical appointments and remind you to take your medication in a compliant way. It can also send you push notifications to remind you of events connected with your MS, if you chose to activate this functionality. It is up to you whether you set up and use the journal and you decide what information you enter into it.
Reports.The app allows you to generate reports based on your journal that can be shared, e.g. with your doctor. This feature allows you to select the information that is provided in your report as well as the date range for that information. Your report will be generated in PDF format and can be shared outside of the app, by whichever means you decide, using the methods made available to you by your device, e.g. e-mail, text message or WhatsApp message.
Nurse chat service. Your personal information mentioned in the “App registration” paragraph above will be accessed by an MS nurse if you choose to use the live nurse chat service. This will allow the MS nurse to chat with you effectively, understand your diagnosis and treatment and to provide you with personalized information and advice. Biogen may also use the information you have provided in your chat when: (a) it is necessary in submitting complaint or adverse event reports to local and international health or pharmaceutical regulators and as otherwise required of us by law (please see the “How we share your information and international transfers” section below); (b) to investigate a complaint made by you about the live chat service; (c) to investigate or resolve a technical problem; and (d) for monitoring and training purposes.
Apple Health or Google Fit app interaction. If you choose to activate this feature, we may collect the following categories of personal information from the relevant app to which you subscribe: activities; mindfulness; nutrition; body measurements; health records; and sleep. This feature is linked to the content that you have provided in your Apple Health or Google Fit app and you will be asked which categories of information you would like to be shared with our app. If you have not recorded any information in your Apple Health of Google Fit app, you will be unable to use this feature. This information is shared via an app interface technology that uses a piece of code enabling it to: (a) verify that you have activated this feature; and (b) send a request for information to your Apple health or Google Fit app. Biogen may share such personal information with an MS nurse if you choose to use the live nurse chat service. We will not share your personal information in the app with your Apple Health or Google Fit app.
Information materials on MS. The app gives you access to articles and videos on MS. Your personal information mentioned in the “App registration” paragraph above will be used to personalise some of this content.
Programs. The app gives you access to videos designed to improve your health and fitness. If you choose to use this feature, we will collect personal information from you, including: what videos you have seen; your rating of any videos you have seen; what programs you have completed; and when you have completed them. We require this information to: (a) provide you with videos or programs that match your profile and preferences; (b) manage the content of the videos or programs that we provide; (c) request your feedback on a video or program; (d) send you a congratulatory message when you have completed a program; and (d) send you a reminder to complete a program that you have not yet finished.
Marketing materials. If you provide your consent by ticking the relevant tick box in the app, Biogen will use your personal information to send you direct marketing communications (including treatment information, insights about MS, clinical trial information, patient education materials and invitations to participate in market research surveys). You may unsubscribe from receiving such communications at any time and you may also manage your preferences in the app.
Data collection technologies, interest-based advertising and “Do Not Track”
Analytics information.If you choose to use the various features of the app mentioned above, the app collects aggregated personal information from you to assess how you are using the app.
(a) Google Analytics - It does this by using specific tagging technology called Google Analytics which provides Biogen with information on what features of the app you use and how frequently you use them. Biogen analyses this information automatically, using an algorithm designed to personalise your experience and to deliver content tailored to your interests. The app also uses Google Analytics to collect aggregated personal information from you to assess: (a) the number of times the app is downloaded; (b) the number of accounts that are created; (c) the amount of times an article is read, a video is viewed or a program is completed; and (d) how the app is being used. This data collection technology allows us to distinguish you from other users of this app, to enhance this app and your experience when you use it, and to send you push notifications if you have selected to receive them.
(b) AppSee - We also use AppSee to analyse users’ behaviour in their usage of the app to improve the user experience.
Online advertising. We also use Firebase, AppsFlyer and DoubleClick Manager, to manage our online advertising program. These data collection technologies are provided by our ad management partners and other third parties. We, and our ad management partners, may use the technologies to track the actions of users of the app, to measure statistics of our marketing efforts, and to deliver advertisements on third party websites. We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance. This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these principles can be found at www.aboutads.info. If you want to “opt out” of receiving online interest-based advertisements, please follow the instructions at www.aboutads.info/choices or www.networkadvertising.org/choices. An “opt-out” cookie will be placed on your device indicating that you do not want to receive interest-based advertisements. If you delete cookies on your device generally, you will need to opt-out again. Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us. It means that the online ads that you do see will not be based on your interests. When you “opt-out” of receiving interest-based advertisements through one of the links above, these data collection technologies may still collect information about your use of the websites, including for analytics.
Notification. Batch - We use Batch to push tailored notifications to you if you have opted in to receive push notifications from the app through your device.
How we share your information and international transfers
Service providers. Biogen engages service providers to assist it in the administration of its data processing activities in relation to the app. These include the companies which: (a) provide Biogen with local MS nurses as part of the live nurse chat service; (b) provide the technology solution to be used for the live nurse chat service; and (c) host the app and your personal information in the cloud and provide Biogen with data storage facilities.
Other Biogen companies.Biogen may also share your personal information with other companies in the Biogen group for the purposes described in this Privacy Notice including Biogen International GmbH, Neuhofstrasse 30, 6340 Baar, Switzerland and Biogen Canada Inc., 90 Burnhamthorpe Rd W #1100, Mississauga, ON L5B 3C3, Canada. If a third party acquires all or a material part of Biogen's business or assets, then your personal information may be disclosed in connection with that sale.
Pharmacovigilance and regulatory requirements. Biogen is obliged by law to comply with regulatory requirements applicable to it as a pharmaceutical company, including the reporting of adverse reactions to its products to monitor the safety of all medicines that we market (also known as our pharmacovigilance or adverse event reporting obligations). Biogen may collect, use and disclose your personal information to other members of the Biogen group and other third parties where it considers this necessary for compliance with applicable laws, to protect the vital interests of any person, or where necessary to exercise, establish or defend Biogen's legal rights.
Ensuring protection of your data.The transfers mentioned above include transfers outside of Canada to countries which may not implement an adequate level of protection for your personal information under Canadian privacy law. Biogen takes appropriate steps to ensure your data is adequately protected if transferred to such countries.
How we store your personal information and your rights
We retain your personal information as long as your account remains active and you may deactivate your account at any time. Your account may be deactivated automatically if you have not used the app for more than 12 months. Before your information is deleted, Biogen will contact you to ask you if you wish your account to remain active. We will also retain your information for as long as is necessary for us to comply with our legal obligations and best practice for a responsible pharmaceutical company.
You may contact Biogen at any time if you would like to access and receive your personal information or require information about the personal information that we hold about you. You may object to the processing of your personal information for legitimate reasons and you may also request the correction or erasure of it. Please note that some of these rights are limited by applicable data protection law and we have the right to collect, process and hold your personal information to perform our legal obligations.
The app is not designed for use by anyone under the age of 18. We do not knowingly make the app available to, or collect personal information from, children under 18. In case we discover that a child under 18 has downloaded the app and provided us with personal information, we immediately delete this from our servers and block access to the app. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to take the necessary action.
Changes to This Privacy Notice
We may update this Privacy Notice from time to time. We advise you to review this page periodically for any changes. If any changes to our Privacy Notice require your further consent, we will contact you to explain the changes and ask to obtain this.
If, at any time, you have questions or concerns about this Privacy Notice or the processing of your personal information, you can contact Biogen by sending an e-mail to [XXX] or by using the “Contact Us” feature within the app. If you choose to use this feature, the app will access the mail application on your device so that you may send us an e-mail. You may also contact Biogen’s Data Protection Officer at firstname.lastname@example.org.
Your data will be securely stored and protected.