This Application may collect Personal Data from Users.

Personal Data may be collected for research into health. This may include data from minors as authorized by their parent or guardian, community level assessments and data gathered in public locations. 

General Research Data Collection 

MEI Research, Ltd is the business that built and maintains the PiLR EMA software Application. We provide the Application as a service for use by Researchers. The Researchers decide what data are collected and own and control the data collected for purposes of a Study under their control (referred to as Research Data). They can create research assessments or surveys that can collect participant data via questions provided in the assessment and from on-board phone sensors (such as the microphone, accelerometer or camera). MEI Research does not collect or access any data, including Research Data, for its own use. MEI Research, through an end-user license agreement (EULA), prohibits Researchers from collecting Protected or Personally Identifiable information and discourages researchers from collecting Personal and Research Data that are not necessary for the Study.

The Application is specifically designed to not collect Identifiable Information stored on your device such as telephone number, email address, IMEI (device identifier), physical address, contacts or any portion of your name. Please be aware that this may prevent MEI Research from helping you restore access to a Study. 

For your information to be collected with this application you must login using a unique user ID and password provided to you by the Researcher. The Researcher is responsible for ensuring that the ID can not identify you (e.g., name; email; phone number, address). Prior to receiving the unique ID and password you should have already reviewed and signed a form consenting to the Study that disclosed what data are collected, who is collecting the data, how data will be managed and how the data will be used. 

We also provide an anonymous login facilitated by scanning a QR code. In this method a computer assigns you a random identifier and connects you to the Study prepared by the Researcher. Neither MEI Research nor the Researcher are able to identify you personally. 

The PiLR EMA application will only collect your Research Data during a scheduled period (which we refer to as your active period). Once this period ends, PiLR EMA will no longer collect and forward data even though the application still is present on your phone or you attempt to open it.

If you downloaded PiLR EMA and do not have a unique ID and password or QR code you will only be able to see a Demonstration, which explains to Researchers how the application can be used. MEI Research will have access to the information gathered by the Demonstration (see Usage Data below).

MEI Research personnel will not access the Research Data, except at the request of a Researcher to fix problems, and only after they grant us access to the data. MEI Research will not use, distribute, rent, resell or otherwise disclose any information, including Research Data and Usage Data, that are collected to any third party except to the Researcher, as directed by the Researcher, or to meet a legal obligation.

Types of Data collected

This Application may collect by itself, or through third parties, Personal Data on behavior, preferences, opinions, location, travel, activity and other measures relevant to health. The Personal Data may be freely provided by you as you answer questions. Or collected automatically (passively), such as by a sensor, when using this Application. Other Personal Data collected may be described in other sections of this privacy policy, by dedicated explanation text in the version of the Application provided to you by the Researcher or in other materials provided to you by the Researcher. Failure to provide certain Personal Data may make it impossible for this Application to provide its services.

The Application does not use “Cookies”. This Application and any third party services may collect files that record interaction with this Application or similar data that are available to the Researcher and that the Researcher may request that MEI Research access to fix problems or for other service purposes (Usage Data). Content entered by the Researcher may link to third party websites to provide relevant information or functionality. MEI Research is not responsible for such external content, which may contain separate privacy policies and data processing disclosures.

You are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that you have the third party’s consent to provide such Personal Data to the Researcher.

Personal Data may be collected using the following and similar services:

Research Assessment or Survey

The Researcher has the ability to create a survey or assessment that collects information from you by soliciting responses to questions. These questions will be presented in surveys that the Researcher may ask to you initiate voluntarily or in response to a prompt programmed by the Researcher. 

Camera, Video and Audio

The Researcher may create an assessment that requests that you take a picture, record a video or audio. You will have the opportunity to grant or withhold permission for PiLR EMA to access the camera or microphone.

Accelerometer and Gyroscope

The Researcher may configure PiLR EMA to read and save data or signals from an accelerometer, gyroscope or other sensor that the Researcher will use to understand your activity.

Location

The Researcher may directly or by choosing a third party process configure PiLR EMA to read and save data or signals from an a GPS receiver, cell tower triangulation (E911 in the USA), and nearby WiFi or other transmitting devices that understand your location and/or the location of certain landmarks, devices or persons relative to your location. The Researcher may use this information to track your movements and interactions, or to prompt you to engage in a survey at a particular location. 

Bluetooth Services

This application may act as a store and forward device for Bluetooth enabled sensors that help the Researcher collect information about your activity.        

Definitions and Additional Material      

Researcher

A Researcher is a natural person who is conducting a Study using this Application. The Researcher is the Data Controller and Owner who makes decisions regarding the purposes, the methods of processing Personal Data and the means used, including the security measures concerning the operation and use of this Application. 

The Researcher will process the Personal Data in compliance with this privacy policy and has authorized MEI Research to assist in this processing. The Researcher may also authorize other natural or legal persons, organizations and services to further assist in processing Personal Data.

Methods of processing

The Researcher is expected to process all data in a proper manner and to take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data. Data are processed using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (software developer, system administration) or external parties (such as third party technical service providers, IT companies). A list of these parties may be requested through the Researcher.

Place

The Data are processed in the cloud and in any other places where parties involved with the processing are located. For further information, please contact the Researcher.

Retention of Data

Data are kept for the time necessary to provide services requested by the Researcher. In some cases the Researcher may ask that data be archived or placed in similar static storage for processing later or as required by the US Government or other agency overseeing the work of the Researcher. The User can request that the Researcher suspend or remove the data.

Data Security, Data Integrity and Access

MEI Research takes reasonable steps to protect information received from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We have physical, technical, and administrative measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption.

International Information Transfers

MEI Research is a United States corporation. Our primary data storage is located in the United States. If you are accessing or using the Application outside the US, you are agreeing to the transfer of your information to the United States.

Legal action

The User’s Personal Data may be used for legal purposes by the Researcher in Court or in the stages leading to possible legal action arising from use of this Application or the related research. The User declares to be aware that the Researcher and MEI Research may be required to reveal Personal Data upon request of a court of law or other public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with information concerning particular services or the collection and processing of Personal Data upon request.

Information not contained in this policy

More details concerning collection or processing of Personal Data may be requested from the Researcher at any time. Please see the contact information in your informed consent.

The rights of Users

Users have the right, at any time, to know what Personal Data has been stored and can consult the Researcher to learn about their contents and origin, to verify accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Researcher as directed in the informed consent.

This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

MEI Research reserves the right to change some or all of this privacy policy at any time by giving notice to Users via this page. We recommend that you check this page, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User may cease using this Application and can request that the Researcher removes Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Researcher has about Users.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Research Data (or Research Information)

Any information collected via sensor or assessment / survey by the Researcher using the PiLR EMA mobile application, including but not limited to, GPS location, activity, accelerometer, camera, microphone, and PiLR EMA assessment / survey(s) during the research period.

Usage Data

Usage Data is information collected from this Application (or third party services employed in this Application) when providing communications or use of resources. This can include: the IP addresses or domain names of the computers used by Users of this Application, Uniform Resource Identifier (URI) and/or internet protocol (IP) addresses, the time of a request, the method used to submit a request to the server, the size of files received, a numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the operating system on the User’s mobile device, various time details per visit (e.g., the time spent on each page within the Application) and certain details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s hardware model and manufacturer.

User

The legal or natural person using this Application and to whom the Personal Data refers.

Revised September, 2019 and April, 2020.