Privacy Policy

Privacy Policy

v1.0

The Preptrack Foundation takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.

We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to Website Visitors (Section 2) and to App Users (Section 3). Sections 1 and 4 are applicable to everyone.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 4.

To the extent we provide you with notice of different or additional privacy policies, those policies will govern such interactions.

1. The Basics

1.1 About us

The Preptrack Foundation is a registered charity (reg. number 1190908) in England and Wales (”we,” “us,” “our,” “Preptrack,” “The Preptrack Foundation,” and “The Foundation”).

1.2 Key terms

In this privacy policy, these terms have the following meanings:

App User” means any person who downloads, installs, or uses any of our mobile applications, including but not limited to Preptrack for iOS.

Websites” refers to our websites, including but not limited to https://preptrack.co.uk.

Website Visitor” means any person who visits our Websites.

Personal Information” means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, email address, gender and sexual identity, or other demographic information.

you” and “your” means, depending on the context, either a Website Visitor or an App User.

PrEP” means oral Pre-Exposure Prophylaxis for HIV prevention.

2. Privacy for Website Visitors

This section applies to Personal Information that we collect and process when you visit our Websites. In this section, “you” and “your” refer to Website Visitors.

2.1 Personal information we collect

When you visit our Websites, we may collect information about you. We use cookies and other identifiers, and other tracking technologies, to collect this information. Our use of cookies and other tracking technologies is discussed more below and in more detail in our Cookie Statement available here.

We currently collect and process the following information:

  • Device and browser information: We collect information about the device and applications you use to visit our Websites, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
  • Usage data: We collect usage data about your interactions with our Websites, which may include dates and times you visited our Websites and your browsing activities (such as what pages are viewed and for how long).

2.2 Use of Personal Information

We use the Personal Information we have collected in order to provide, support and improve our Websites and other service offerings.

We may share this information with our third-party analytics service provider, “Google Analytics”. For the purposes of the General Data Protection Regulation (GDPR), The Foundation is a Data Controller and the provider of Google Analytics, “Google LLC”, is a Data Processor. Personal Information processed by Google Analytics is also subject to and processed in accordance with the “Google Privacy Policy”, available here. Further information on the way Google LLC processes information from our Websites can be found here.

Under the General Data Protection Regulation (GDPR), the lawful basis we rely on for processing this information is:

Your consent. We only collect Personal Information about you on our Websites if you explicitly opt-in to this collection. You are able to remove your consent at any time. You can do this by contacting dpo@preptrack.co.uk or by clearing your browser’s cookies

2.3 How we store Personal Information

Your information is securely stored by Google Analytics. We keep this Personal Information for at most 26 months, after which it will be automatically deleted by Google Analytics.

3. Privacy for App Users

This section applies to Personal Information that we collect and process when you download, install, or use our mobile applications. In this section, “you” and “your” refer to App Users.

3.1 Necessary Personal Information we collect

When you use our mobile applications, we will collect necessary information about you in order to provide essential functionality. This information is stored securely on your device, and is not accessible to anyone other than you.

We currently collect and process the following information:

  • Medical and health information: We collect information about your health, such as your HIV status, kidney function, your use of certain medicines such as feminising hormones, and the times and dates of your PrEP doses.
  • Sex life information: We collect information about your sexual practices, such as the time of your most recent sexual activity.

3.2 Use of Necessary Personal Information

We use the Necessary Personal Information we have collected in order to provide the essential functionality of our mobile applications. We only collect the miminum amount of Necessary Personal Information that is required to the enable the proper functioning of our mobile applications.

Under the General Data Protection Regulation (GDPR), the lawful basis we rely on for processing this information is:

Your consent. We only collect Necessary Personal Information about you in our mobile applications if you agree to the terms of this privacy policy.

You are able to remove your consent at any time. You can do this by contacting dpo@preptrack.co.uk or by uninstalling the mobile application.

3.3 How we store Necessary Personal Information

Your information is securely stored on your device, and is not accessible to anyone other than you. We keep this Personal Information until you uninstall the mobile application from your device.

3.4 Personal Information we collect for Analytics

When you use our mobile applications, we may collect information about you. We use identifiers and other tracking technologies to collect this information.

We currently collect and process the following information:

  • Device information: We collect information about the device you use to access our mobile applications, such as, your IP address, your operating system, and other information about your system and connection.
  • Crash reporting and feedback: We collect information about when things go wrong, such as when our mobile applications crash, or when you report bugs or other feedback.
  • Usage data: We collect usage data about your interactions with our mobile applications, which may include dates and times you used our mobile applications and your activities (such as what parts of the app are viewed and for how long).

3.5 Use of Personal Information for Analytics

We use the Personal Information for Analytics we have collected in order to provide, support and improve our mobile applications and other service offerings.

We may share this information with our third-party analytics service providers, “Google Analytics” and “Firebase”. For the purposes of the General Data Protection Regulation (GDPR), The Foundation is a Data Controller and the provider of Google Analytics and Firebase, “Google LLC”, is a Data Processor. Personal Information processed by Google Analytics and Firebase is also subject to and processed in accordance with the “Google Privacy Policy”, available here. Further information on the way Google LLC processes information from our Websites can be found here.

If you are an alpha or beta tester, we may receive information about your usage of our mobile applications through “TestFlight”. This information will relate to when our mobile applications crash, or when you provide feedback about our mobile applications. For the purposes of the General Data Protection Regulation (GDPR), The Foundation is a Data Controller and the provider of TestFlight, “Apple Inc.”, is a Data Processor. Personal Information processed by TestFlight is also subject to and processed in accordance with the “Apple Privacy Policy”, available here, and the “TestFlight Terms of Service”, available here. Further information on the way TestFlight processes information from our mobile applications can be found here.

Under the General Data Protection Regulation (GDPR), the lawful basis we rely on for processing this information is:

Your consent. We only collect Personal Information for Analytics about you on our mobile applications if you explicitly opt-in to this collection. You are able to remove your consent at any time. You can do this by contacting dpo@preptrack.co.uk or changing your privacy settings in the mobile application.

3.6 How we store Personal Information for Analytics

Your information is securely stored by Google Analytics and by Firebase. We keep this Personal Information for at most 26 months, after which it will be automatically deleted by Google Analytics and by Firebase.

If you are an alpha or beta tester, information regarding crashes and feedback is securely stored by TestFlight. We keep this information for at most 1 year, after which it will be automatically deleted by TestFlight.

4. General Information

4.1 Your data protection rights

Under data protection law, you have rights including:

Your right of access

You have the right to ask us for copies of your personal information.

Your right to rectification

You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing

You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability

You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at dpo@preptrack.co.uk if you wish to make a request.

4.2 How to contact us

If you have questions, comments, or requests, you can contact us as at:

Contact details

The Preptrack Foundation Unit 50345 PO Box 6945 London W1A 6US

Email: dpo@preptrack.co.uk

Website: https://preptrack.co.uk

4.3 How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at dpo@preptrack.co.uk or using the contact details above.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk