Use of our mobile app
I. Information on the collection of personal data
(1) We provide you with a mobile app (“CURIA“) that you can download to your mobile device. In the following, we provide information about the collection of personal data when using CURIA. Personal data are all data that can be personally related to you, e.g. name, address, email addresses, user behavior.
(2) The person responsible as controller in accordance with the Art. 1 of law No. 30 of 2018 on Personal Data Protection in the Kingdom of Bahrain (Bahrain Data Protection Law) and Art. 4 para. 7 of the EU General Data Protection Regulation (GDPR) is (“Innoplexus“).
The company data protection officer of Innoplexus can be contacted at the above address, at Datenschutzabteilung, or at email@example.com.
(3) When you contact us via email or a contact form, we will store your email address and, if you have provided it, your name and telephone number to answer your questions. We delete the data arising in this connection after storage is no longer required or – in the case of legal storage obligations – restrict processing.
(4) If we use contracted service providers for individual functions of our offer or wish to use your data for advertising purposes, we will inform you in detail about the respective processes below. We will also state the specified criteria for the storage period.
II. Processing of personal data when using CURIA
When using CURIA, your personal data will be transmitted and processed outside your country or the country of your habitual residence, and you expressly declare your acceptance to such cross-border transmission and processing of your personal data every time you use CURIA or provide us with any of your personal data for processing.
By uninstalling, the active processing of your personal data is stopped. 30 months from the date of uninstalling, the data will be deleted due to the discontinuation of purpose, unless we are subject to any statutory retention obligations. We accept the loss of purpose after this period because we assume that it is no longer likely that you will use our services again after this period. However, in order to give you the opportunity to restore your profile after a shorter period of time, e.g. because you deleted the app earlier for lack of necessity, we temporarily store the data for you.
However, if you wish to revoke your consent and not just temporarily suspend its use, you can do so by clicking the “Delete all my personal data” button.
§1 When using CURIA, we collect the following log file data:
– IP address, also in the API logs
– Date and time of the request
– Content of the request (concrete page, concrete API endpoint)
– Access Status/HTTP Status Code
– Amount of data transferred in each case
– End device from which the request comes
– User Agent
– Operating system and its interface
– Language and version of the User Agent.
On the one hand, this data is mandatory for us from a technical point of view in order to offer the various functions of CURIA as well as to ensure the stability and security of CURIA and, on the other hand, to enable a comfortable use of the functions. This processing purpose also represents the legitimate interest and/or is necessary for the performance of this contract which, according to Art. 4 para. 1 and para. 5 of Bahrain Data Protection Law / Art. 6 para. 1 lit. b and f GDPR, is the legal basis for data processing.
IP addresses in log files are deleted after 14 days.
§2 Furthermore, when CURIA is started for the first time, we assign a unique installation ID for each installation, which is stored on an Innoplexus server. It contains no personal data. If you delete CURIA and then reinstall it, a new installation ID will be generated. This will be assigned so that a connection to the Innoplexus server can be established when starting CURIA on the mobile device to check if the version of CURIA you are using is still up to date. CURIA can be updated to implement new features or to ensure data security.
§3 You must register with your first and last name, e-mail address, telephone number in order to take advantage of CURIA’s free services. This creates a contract of use between Innoplexus and you and you will receive your own user account. The legal basis for this is Art. 4 para. 1 and para.5 of Bahrain Data Protection Law / Art. 6 para. 1 p. 1 lit. b GDPR, because we use this personal data for the execution of this contract. The data you provide will be transferred to the Google Cloud and stored on a server in Germany. The Google Cloud is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA. We have concluded so-called standard contractual clauses with Google, which guarantee an appropriate level of data protection.
You can delete your account at any time by clicking the “Delete my personal data” button within CURIA. The personal data processed by us will be deleted in accordance with Art. 23 of Bahrain Data Protection Law / Art. 17 GDPR or blocked or restricted in their processing in accordance with Art. 23 of Bahrain Data Protection Law / Art. 18 GDPR. The data stored by us will be deleted as soon as the purpose of storage no longer applies and the deletion is not contradicted by any legal storage obligations.
§4 If you would like to receive information about possible treatment options, physicians and clinical studies, you can fill out the questionnaire provided by us with questions about your clinical picture. Cancer-specific parameters will be asked, such as information on genetic mutations, the status of the respective cancer, etc. The information you provide is voluntary and serves the sole purpose of enabling us to provide you with information.
The processing is based on your consent (Art. 24 para. 1 and para.2 of Bahrain Data Protection Law / Art. 6 para. 1 lit. a GDPR). You are free to revoke your consent at any time with effect for the future without giving reasons. This does not affect the legality of the processing carried out up to that point.
You also have the option of registering for participation in clinical studies. To do so, you must provide the following information: Information about the study you wish to register for, your location, contact information (telephone number or e-mail address), information about your medical inclusion and exclusion criteria. The provision of this personal data is voluntary and is based on your consent (Art. 24 para. 1 and para.2 of Bahrain Data Protection Law / Art. 6 para. 1 lit. a GDPR). The purpose of the processing is to carry out the selection procedure. You are free at any time to revoke your consent with effect for the future without giving reasons by selecting the option “Delete all my personal data” in the app.
This gives you the option to delete all personal data. After clicking on the “Delete all my personal data” option, you will receive an automated email confirming the deletion of your data. This does not affect the lawfulness of the processing that took place until the revocation.
The completed questionnaires and applications for participation in clinical trials are transferred to the Google Cloud and stored on a server in Germany. The Google Cloud is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA. We have concluded so-called standard contractual clauses with Google, which guarantee an appropriate level of data protection. If you have met all eligibility criteria for the clinical trial request, the personal data you have provided will be transferred to the internal Innoplexus clinical trial dashboard.
This data can be accessed by the CURIA team, which is partly based in India and is part of Innoplexus Pune. Here, an appropriate level of data protection is ensured through the conclusion of standard contractual clauses.
§5 We use Google Analytics and Google Firebase, both services provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, to
Your IP address will be processed. We use the anonymization function of Google, whereby the IP address is shortened in the EU/EEA for anonymization purposes and is transmitted in shortened form to Google servers in the USA. We use the anonymized reports on the general use of CURIA created by Google and transmitted to us in order to continuously improve our service and increase the user-friendliness of CURIA. The reports we receive contain no personal data. We process the information for the aforementioned purposes on the basis of your previously granted consent in accordance with Art. 24 para. 1 and para.2 of Bahrain Data Protection Law / Art. 6 para. 1 lit. a GDPR.
The data is processed in the USA, for which we have so-called standard contractual clauses with Google that guarantee an appropriate level of data protection.
The data will be deleted when they are no longer necessary for the purpose of their collection because the option to collect and further process information on diagnosis and usage behavior in CURIA has been deactivated.
You are free to revoke your consent at any time with effect for the future without stating reasons. This does not affect the legality of the processing that has taken place up to that point.
III. Processing of personal data when using the Cancer Twin feature
A Cancer Twin is a patient in the Curia community whose cancer diagnosis is similar to yours. Cancer Twins can use a private chat to share experiences. The chat is based on Ethereum blockchain technology. The aim of the new feature is to bring cancer patients together.
§ 1 As part of a matching process, you as a user will be matched together with up to 3 other cancer patients, Cancer Twins, who have activated this feature and have a similar profile. In order to find a matching Cancer Twin, the following parameters are compared, which we collect from you to carry out the matching process:
– Cancer indication
– Hormone receptors
– Genetic markers
– Other health data, depending on cancer type
The purpose of this feature is to bring together cancer patients and promote the exchange of experiences and information between patients who have a similar cancer diagnosis. The processing is based on your explicit consent (Art. 24 para. 1 and para.2 of Bahrain Data Protection Law / Art. 6 para. 1 lit. a GDPR). You are free to revoke your consent at any time without giving reasons with effect for the future. This does not affect the legality of the processing carried out up to that point.
If the last login date is more than 6 months ago, the corresponding profile is automatically removed from the database and can no longer be matched with new Cancer Twins.
§ 2 Cancer Twins can exchange information in a chat integrated in CURIA. Patients must register for the feature and select a nickname before being matched with their Cancer Twin(s). This nickname can be edited in the settings. When users exchange messages via the built-in chat, the end-to-end encrypted messages are stored on a public Ethereum blockchain.
For this purpose, Innoplexus has provided a node that takes on the function of an intermediary to forward the chat message to the Ethereum blockchain. Before a message is transmitted and stored on the blockchain, it is fully encrypted locally on the patient’s mobile device using end-to-end encryption. The private key needed to encrypt the message is stored on your physical device the whole time and is not shared with Innoplexus or other users. Only when the encrypted message is received by the Cancer Twin, this message is decrypted with a corresponding key on the mobile device of the Cancer Twin who is to receive the message.
The purpose of this chat function is to enable the exchange of information and experiences in a simple way and without big hurdles, offering at the same time a high level of security. The processing is based on your consent (Art. 24 para. 1 and para.2 of Bahrain Data Protection Law / Art. 6 para. 1 lit. a GDPR). You are free to revoke your consent at any time without giving reasons with effect for the future. This does not affect the legality of the processing carried out up to that point.
In this case, the chat associated with your profile will be deleted from your device. In this case, the private key is lost and no one can decrypt the data, not even CURIA or Innoplexus AG. The nickname and chat content on the device of the Cancer Twin with whom messages were exchanged also disappear. Besides this, your profile will be automatically removed from the Cancer Twin database if the last login date is more than 6 months ago.
The server location cannot generally be assigned to a specific country due to the blockchain infrastructure (Public Ethereum blockchain), but by encrypting the chat content using a public key encryption method, the data is highly pseudonymised for everyone else, so that a data transfer to a third country can be considered “safe”.
Hashed metadata is not stored on the Ethereum blockchain.
We will only send you marketing information electronically (e.g. by email) only when you have actively provided your consent to us for this processing. We will contact you to let you know about the progress we are making against the latest research developments, advice, on our products and services etc. We also notify you about the introduction of new functions, announce the conclusion of new partnerships and what this means for you when using CURIA.
You can withdraw your consent at any time by clicking the Unsubscribe; link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
V. Your rights
Besides the information provided to you above, as we shall obtain personal data directly from you, we shall provide you upon registration of such data, with any further information which is necessary, having regard to the specific circumstances in which the data are to be processed and to ensure the processing is fair to you. Such information to be provided to you shall include the names of the recipients of the data or the categories of recipients, whether replies to any questions we ask you for the purpose of the processing are obligatory or voluntary, as well as the possible consequences of failure to reply.
(1) Besides the above, you have the following rights towards us regarding your personal data:
– Right of access – Art. 18 of Bahrain Data Protection Law / Art.15 GDPR,
– Right to rectification or erasure – Art. 23 of Bahrain Data Protection Law / Art.16 and 17 GDPR,
– Right to restriction of processing – Art. 23 of Bahrain Data Protection Law / Art.18 GDPR,
– Right to object to the processing – Art. 21 of Bahrain Data Protection Law / Art.21 GDPR,
– Right to data portability –Art.20 GDPR,
– Right of withdrawal according to Art. 24 para. 3 of Bahrain Data Protection Law / Art. 7 para. 3 GDPR
(2) You also have the right to complain to a data protection supervisory authority of your choice, or that of the country of your habitual residency about the processing of your personal data by our association. Responsible for us is the
Hessische Beauftragte für Datenschutz und Informationsfreiheit Gustav-Stresemann-Ring 1
65189 Wiesbaden, Germany
Phone: +49 (0) 611 14080
The Competent authority Under the Data Protection Law of the Kingdom of Bahrain is:
PERSONAL DATA PROTECTION AUTHORITY
Tel: (+973) 175 133 14
(+973) 175 133 21
(+973) 175 133 41
For every natural person who is habitually resident in the Kingdom of Bahrain or maintains a place of business therein, the applicable law regarding the protection their personal data is the Data Protection Law No. 30 of 2018. The mandatory terms of that law will be applicable and should prevail over any of the above-stated terms and GDPR provision in case of contradiction. A full copy of that law is available on the Personal Data Protection Authority website at http://www.pdp.gov.bh/en/regulations.html