Ruma Digital-System (Pro) Privacy Policy
Ruma Digital-System collects personal data from its users. Due to the sensitivity of medical data, all data are encrypted before transmission while still on the user’s terminal device. Only the attending physician authorised by the user directly will be able to decrypt the data. Any other parties involved in this process shall only render services for processing, without having any access to the end-to-end encrypted data.
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Summary of the Privacy Policy
Personal data collected for the following purposes and using the following services:
Device permissions for access to personal data
-Device permissions for access to personal data
Personal data: Camera permission; microphone permission; memory permission
Processing of personal data
- Anonymised patient data
- Patient consent and version of the consent text
- Patient app ID, encrypted, with time stamp
- ID of the markers handed out, encrypted, with time stamp
- Reference to encrypted video file, with time stamp
- Result of the doctor’s assessment after viewing the video, with time stamp
- Transport data
IP address of user device, used browser, used video player
Platform services and hosting
Apple app store
Personal data: Usage data
Push notifications
Ruma Digital-System (Pro) may send push notifications to the user for the purposes listed in this privacy policy.
In most cases, users may opt out of receiving push notifications in their device settings, e.g. for mobile message alerts, by changing the settings for the Ruma physician and patient apps, for some, or for all apps on the respective device.
Users must be aware that disabling push notifications may impair Ruma Digital-System (Pro) and its use.
Distributor
Ruma GmbH
Wilhelm-Schlombs-Allee 1
D-50858 Cologne, Germany
Distributor’s email address: info@marker-test.de
Full Privacy Policy
Types of Collected Data
The personal data processed by Ruma Digital-System (Pro) independently or through third parties include: Camera permission; microphone permission; memory permission; usage data (patient consent and consent text version; patient app identifier, encrypted, with time stamp; issued marker identifier, encrypted, with time stamp; reference to encrypted video file, with time stamp; result of physician’s assessment after viewing the video, with time stamp). Complete details on all types of personal data processed will be provided in the designated sections of this privacy policy, or specifically by way of explanatory texts displayed before data collection.
Personal data may be provided freely by the user or, in the case of usage data, may be collected automatically while using Ruma Digital-System (Pro).
Except where otherwise specified, provision of any data requested by Ruma Digital-System (Pro) is mandatory. If the user refuses to provide the data, Ruma Digital-System (Pro) may be unable to render its services to the user. If Ruma Digital-System (Pro) explicitly states that the personal data are provided freely, users may choose not to provide such data without any effects on availability or function of the service.
Users who are unsure about what personal data are mandatory may contact the distributor.
Type and Location of the Processing Activities
Processing methods
The distributor shall process the user data properly, taking appropriate security measures to prevent unauthorised access and unauthorised disclosure, modification, or destruction of data.
Processing activities shall be performed by way of computers or IT-based systems in accordance with organisational procedures and practices specifically designed to meet the stated purposes. Persons other than the controller may have access to Ruma Digital-System (Pro) data, either internally (e.g. system administrators) or externally, in which case they may be designated as processors (such as technical service providers, hosting providers, physicians) by the controller. However, only the authorised attending physician has decrypted access to the data. Any other parties only render the service; the data are encrypted end-to-end in a blockchain and cannot be decrypted by anyone other than the attending physician. An up-to-date list of the parties involved, and the data stored from case to case may be requested from the distributor at any time.
Legal basics of processing
The distributor must only process personal data of users in the following cases:
• The users have consented to one or several specific purposes.
• Collection of the data is necessary for performance of a contract with the user and/or for pre-contractual actions connected to it;
• Processing is required to comply with a legal obligation imposed on the distributor;
• Processing is related to a task performed in the public interest or in the exercise of official authority vested in the distributor;
• Processing is required due to the distributor’s or a third party’s legitimate interest.
In any case, the distributor will gladly provide information on the specific legal basis for processing, in particular on whether provision of personal data is a legal or contractual obligation or a condition for conclusion of a contract.
Location
The data shall be processed at the distributor’s office and in any other location where the bodies involved in processing activities are located.
Data transfers may involve transfer of the user’s data to a country other than the user’s own, depending on the user’s location. Users may consult the section with the detailed information on processing of personal data to learn more about the place of processing of the transmitted data.
Storage duration
Personal data shall be processed and stored for as long as this is required for the purpose for which they were collected.
The following applies as a result:
• Personal data collected for the purpose of fulfilling a contract between the distributor and the user shall be stored until the contract has been fully met.
• Personal data collected for the purpose of protecting the distributor’s legitimate interests shall be kept for as long as is required to meet those purposes. Users may obtain more detailed information on the distributor’s legitimate interests in the relevant sections of this document or by contacting the distributor.
Beyond this, the distributor may store personal data for a longer period of time if the user has consented to such processing activities, provided that the consent has not been withdrawn. Beyond this, the distributor may be obligated to keep personal data for a longer period of time if this is required to comply with a legal obligation or based on the order of a public authority.
Personal data shall be erased after the end of the archiving period. Therefore, the right of access, the right of erasure, the right of rectification, and the right of data portability cannot be exercised after expiration of the archiving period.
Purposes of Processing
Personal data concerning the user shall be collected to enable the distributor to provide the service and also to comply with its legal obligations, to respond to enforcement requests, to protect its rights and interests (or those of users or third parties), and to detect malicious or fraudulent activities. Beyond this, data are collected for the following purposes: Device permissions to access personal data and platform services and hosting.
Users can find more detailed information on these processing purposes and the personal data used for each specific purpose in the relevant sections of this document.
Device Permissions for Access to Personal Data
Ruma Digital-System (Pro) may request certain permissions that allow it to access the user’s device data as described below, depending on the user’s device.
The user usually needs to grant these access permissions before the corresponding information can be accessed. The user can withdraw consent once granted at any time in the menu item “Data Privacy”.
Note that Ruma Digital-System (Pro) will be unable to function correctly if such permissions are withdrawn.
If the user grants any of the permissions listed below, the respective personal data may be processed (i.e. accessed, modified, or removed) by Ruma Digital-System (Pro).
Camera permission
Required for accessing the camera or taking pictures and videos from the device.
Microphone permission
Permits access to the microphone and audio recording via the user’s device.
Memory permission
Is used to access shared external storage, including reading and adding objects.
Detailed Information on Processing Activities Concerning Personal Data
Personal data are collected for the following purposes and using the following services:
Device permissions for access to personal data
Ruma Digital-System (Pro) requests certain approvals from users that give it access to the user device data as described below.
Processed personal data: Camera permission; microphone permission; memory permission; usage data (patient consent and consent text version; patient app identifier, encrypted, with time stamp; issued marker identifier, encrypted, with time stamp; reference to encrypted video file, with time stamp; result of physician’s assessment after viewing the video, with time stamp). Furthermore, the IP address of the user's device, the browser they use, and the video player they use, if applicable, are being processed when accessing the introductory video.
Platform services and hosting
These services are to host and operate main components of the Ruma Digital-System (Pro) application, allowing the provision of Ruma Digital-System (Pro) on a consistent platform. Such platforms provide the distributor with a number of tools that include processing of personal data.
Some of these services use geographically dispersed servers. This makes it difficult to determine where personal data are stored.
Apple App Store (Apple Inc.)
Ruma Digital-System (Pro) is distributed on Apple’s App Store, a mobile application distribution platform provided by Apple Inc.
Apple collects basic usage statistics and provides reporting capabilities that allow the distributor to view usage statistics and measure the performance data of this application (Ruma physician and patient apps) by distributing this application via this channel.
Most of this information is processed on an opt-in basis. Users can disable this analysis function in their device settings directly. The user can find more information on managing the analysis settings on this page.
Processed personal data: Usage data.
Processing location: United States of America – Privacy Policy. Privacy Shield Member.
Push notifications
Ruma Digital-System (Pro) may send push notifications to the user for the purposes listed in this privacy policy.
In most cases, users may opt out of receiving push notifications in their device settings, e.g. for mobile message alerts, by changing the settings for the Ruma physician and patient apps, for some, or for all apps on the respective device.
Users must be aware that disabling push notifications may impair Ruma Digital-System (Pro) and its use.
User Rights
Users may exercise certain rights concerning their data processed by the distributor.
Users who are entitled to more comprehensive standards may exercise any of the rights described below. In all other cases, users may ask the distributor about the rights applicable to them.
In particular, users have the right to do the following:
- Withdraw consent at any time. If the user has previously consented to processing of personal data, they may withdraw their consent at any time.
- Object to processing of their data. The user has the right to object to processing of their data if processing has any other legal basis than consent. Further information on this is provided below.
- Be informed about their data. The user has the right to know whether the data are processed by the distributor, to obtain information on individual aspects of processing, and to inspect the data on the physician’s premises.
- Review and have them corrected. The user has the right to verify accuracy of their data and to request an update or correction.
- Request restriction of processing of their data. Users have the right to restrict processing of their data in certain circumstances. In this case, the distributor shall not process the data for any other purpose than storage.
- Request erasure or other removal of the personal data. Subject to certain circumstances, users have the right to request the erasure of their data from the distributor.
- Have their data transferred to another controller. The user has the right to have their data transferred to a different controller. This must also be a physician who uses Ruma Digital-System since the encryption chain would be broken otherwise. This provision is applicable as far as the data are processed automatically and processing is based on the user’s consent.
- Lodge a complaint. Users have the right to lodge a complaint with the competent supervisory authority.
Details of the right to object to processing
If any personal data are processed in the public interest, exercising a public authorisation vested in the distributor or in order to protect the distributor’s legitimate interests, the user may object to such processing by stating a justifying reason concerning their particular situation.
Users are informed that they may object to processing of personal data for direct marketing purposes at any time without giving any reasons. Users can learn whether the distributor processes personal data for direct marketing purposes in the relevant sections of this document.
Exercising the rights
All requests to exercise user rights may be addressed to the distributor using the contact details provided in this document. Requests may be filed free of charge. They shall be processed by the distributor as soon as possible and at the latest within one month.
Further Information on Data Collection and Processing Activities
Legal measures
The distributor may process the user’s personal data for the purposes of law enforcement within the scope of, or in preparation for, legal proceedings arising from improper use of Ruma Digital-System (Pro) or its affiliated services.
The user confirms that they are aware that authorities may require that the distributor disclose personal data.
Further information about the user’s personal data
In addition to the information set forth in this privacy policy, Ruma Digital-System (Pro) may provide the user with additional contextual information concerning specific services or collection and processing of personal data upon request.
System logs and maintenance
Ruma Digital-System (Pro) and third-party services may collect files that record interaction via Ruma Digital-System (Pro) (system logs) or use other personally identifiable information (such as the IP address) for operational and maintenance purposes. Personal data are always encrypted and can only be viewed by the user’s own physician.
Information not included in this privacy policy
Further information on the collection or processing of personal data can be requested from the distributor via the contact details given at any time.
Changes to this privacy policy
The distributor reserves the right to make changes to this privacy policy at any time by informing users on this page and, if applicable, via Ruma Digital-System (Pro) and/or, as far as this is technically and legally possible, by sending a message via the users’ contact details available to the distributor. As a result, users are asked to visit this page periodically, and to check in particular for the date of the last modification indicated at the bottom of the page.
Where any changes concern data use based on the user’s consent, the distributor shall obtain a new consent if necessary.
Definitions of terms and legal notices
Personal data (or data)
Any information that, directly or in combination with other information, identifies or may identify a natural person.
Usage data
Information automatically collected by Ruma Digital-System (Pro) (or third-party services that Ruma Digital-System (Pro) uses), such as: the IP addresses or domain names of the computers of users using Ruma Digital-System (Pro), the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to send the request to the server, the size of the response file received, the numerical code indicating the status of the server response (successful result, error, etc.), the country of origin, the functions of the browser and operating system the user uses, the various time indications for each call (e.g., how much time was spent on each page of the application), and information about the path the user followed within an application, in particular the sequence of pages visited, as well as other information on the operating system of the device and/or the IT environment of the user.
User
The person using Ruma Digital-System (Pro).
Data subject
The natural person the personal data refer to.
Processor (or data processor)
Natural person or legal entity, public authority, agency, or other body processing personal data on behalf of the controller as described in this privacy policy.
Ruma Digital-System (Pro) (or this application)
The hardware or software tool used to collect and process the user’s personal data.
Service
The service provided by Ruma Digital-System (Pro) as described in the relevant terms of use (if applicable) and on this page/in this application.
European Union (or EU)
Unless otherwise stated, all references to the European Union in this document refer to all current member states of the European Union and the European Economic Area (EEA).
Legal notice
This privacy policy has been drawn up based on provisions of various legislations, including Article 13/14 of Regulation (EU) 2016/679 (the General Data Protection Regulation).
This privacy policy applies solely to Ruma Digital-System (Pro).
Last update: 11 January 2023