Privacy Policy
Astellas Pharma Australia Pty Ltd., based in Suite 2.01, 2 Banfield Road Macquarie Park, NSW 2113 (“Astellas“) respects your right to privacy. The Privacy Policy explains who we are, how we collect, share and use personal information about you when you use the iCOMMIT application (the “Personal Information”). 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 bottom of this Privacy Notice.
Astellas is part of the Astellas global pharmaceutical business, whose ultimate parent company is headquartered in Tokyo, Japan. Astellas is a pharmaceutical company committed to turning innovative science into value for patients. Changing tomorrow is the ethos that guides everything we do. For more information about Astellas, please see the “About” section of our Website at https://www.astellas.com/au
Please note that the iCOMMIT application has been developed by a vendor, Incuna Asia Pacific Pte. Ltd., based at 3 Church Street Level 8 Samsung Hub Singapore 049483 (“Incuna“). Incuna will have access to the Personal Information mentioned below that you may provide when you are using the iCOMMIT application. Personal Information are not shared with Astellas in any case.
This mobile application (“App”), has been developed by Incuna and sponsored by Astellas. Incuna is responsible for all aspects relating to the management of the application, including uploading app content, maintaining app operations, ensuring app security as well as handling data enquires. Astellas is not responsible for managing any aspect of this app.
1.1 The collection, use and disclosure of your Personal Information is governed by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (the Privacy Act), the terms of which are also incorporated into this Agreement by reference and apply to your use of our App and the App Functions as described in the “iCOMMIT MOBILE APP TERMS AND CONDITIONS”. Incuna takes your privacy seriously. In dealing with personal information, we comply with the Privacy Act and any relevant state or territory privacy legislation.
1.2 It is a continuing condition of your use of the App and App Functions that you agree to the terms of the present Privacy Act as amended from time to time. We reserve the right to update or modify this Privacy Act at any time without prior notice. Your continued use of the Services after any changes or revisions to this Privacy Act shall denote your Agreement with the terms of such a revised Privacy Act.
1.3 Incuna collects Personal Information via user inputted data and through the use of cookies and other technologies to improve and upgrade the app, including details of your visits to the App, traffic data, IP address, location data, operating system, browser type.
1.4 Incuna may collect Personal Information from you whenever you provide this to us when you register / administer your account, visit certain portions of the App, or report / administer problems in connection with the use of the App, including:
● Biographical and medical Information, including:
○ First Name
○ Date of Birth
○ Gender
○ Email address
○ Date of Transplant
○ User’s Transplant Centre
○ User’s ongoing care centre
○ Organs that were transplanted
○ User’s treatment
● Intra-patient Variability
○ Tacrolimus target trough or target range
○ Tacrolimus daily dose
○ Tacrolimus actual trough
● Lab test image
● Creatinine levels
● Blood pressure
● Weight
● Liver Function
○ Alanine transaminase
○ Aspartate aminotransferase
○ Albumin test
○ Total bilirubin test
● Appointment reminder data
○ Location and time/date of reminder
● Treatment reminder
○ Medication name
○ Date/time
○ Dose
● Cookies:
○ A cookie is a small data file that often includes an anonymous, unique token, which is sent to your App and may be stored on your Device. Cookies do not store any Personal Information.
○ Session Cookies are temporary cookies that remain only until you log out of the App. Session Cookies do not store any Personal Information, only a unique visitor ID number that may be used to ensure users are properly authenticated and can view App information.
○ Persistent Cookies remain in the cookie file of your browser for much longer, even after you leave the App. Persistent Cookies also do not store any Personal Information. Persistent Cookies store preferences that should persist from visit to visit, like “Remember Me,” and a unique token to enable us to understand how users use the App (“App Usage”).
1.5 By using, accessing and inputting information in the App, you agree that any and all (excluding personal information) that you have entered or may enter at a future time, into the App, as well as any data you may enter into related features or Services of the App (which are not present at the moment within the App, but which may be introduced at any time in the future), you consent to the compilation, processing, analysing as well as anonymous disclosure of the resulting statistics to a third party. Under the Privacy Act consents can be revoked at any time. If this occurs we will take all reasonable steps to cease using the image or photo from the time the consent is withdrawn.
The main objectives of data collection are to improve the understanding of transplants. In lieu of these objectives, the above-mentioned compilation, processing, analysis, and anonymous disclosure of data may be conducted with the purpose of:
● System-level actions, such as administration of the App in general; App security purposes; authentication or validation of your identity for your use of the App; supporting the operations in connection with the App and your use of the App; creating and maintaining a record for legal / investigative purposes or preservation of evidence in proceedings involving Incuna’s provision of the App or your use of the App; enforcement of Incuna legal rights in connection with the App or your use of the App; protection against / mitigation of / prevention of harm and damage arising from the operation of the App / your use of the App; analyzing the App and the services, functions or features for improvement of user experience or any other aspect of the System; or reporting to regulatory authorities as may be required of Incuna by law or regulation including the production of information upon legally enforceable requests / orders / directives as may be required (collectively, the “System Purposes”)
● Developing anonymous aggregated reports, analysis, charts, tables, infographics which may be shared with Astellas
● Possible work with external researchers to improve understanding of transplant outcomes
● Compare different transplant outcomes population groups for our understanding
● Quantifying how Incuna’s services are utilized
● Developing consequently related new products, services and features which may be used to improve the App or may be sold to you or a Third Party
All and any data you enter into the App shall be treated with absolute anonymity and any information that is provided to a Third Party in the form, including aggregated reports, shall not include any personal information, including all data recorded during registration.
All of Incuna’s servers are highly secure, and security checks are made on a routine basis. All data that is stored onto the servers are encrypted, and strict access controls are established to restrict who can view any data.
Personal data provided by you will be retained as long as the purpose for which the data was collected continues. Thereafter, Incuna will destroy or delete the information, or remove the means by which the data can be associated with you, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect Incuna’s interests. Incuna may continue to use statistics resulting from your aggregated data entries indefinitely after you deactivate your account.
Based on your prior consent, we may share your name, email and contact number with your registered transplant centre and ongoing care centre. This is to ensure that these centres have an updates means of communicating with you as a routine part of your care.
We may also use or disclose your personal information:
● For the purposes for which we collected it;
● For other purposes to which you have consented; and
● As otherwise authorised or required by law.
1. 6 Personal Information that you provide to Incuna can be modified by you within your iCOMMIT app account (e.g. modifying your user email address). If you remove data from your account, it will no longer appear to you.
1.8 We as the app vendor have undertaken a thorough examination of the app in line with expectations set out in the Therapeutic Goods Act 1989 and Therapeutic Goods (Articles that are Medical Devices) Specification 2014. Vendors are required to assess whether any software used in the healthcare setting is considered Software as a Medical Device, and as such we have concluded that the app is excluded from Therapeutic Goods Administration (TGA) oversight.
1.9 You can deactivate your iCOMMIT account by either selecting deactivate in the settings of the App or by contacting icommit@incuna.asia from your user’s email address. When you do, data that can identify you will be removed from the servers, including but not limited to your email, name, symptom data, etc. Backup copies of this data will be removed from our server based upon an automated schedule, which means it may persist in our archive for a short period.
1.10 Under the Privacy Act you have the right to access the personal information we hold about you. There are some limited exceptions to this set out in the Privacy Act.
If you make an access request, Incuna will ask you to verify your identity and to specify what information you require. We may ask the reason for your request so we can assist you most effectively. However, you are under no obligation to provide a reason if you do not wish to.
You also have a right to request that we correct information held by us that you consider is not accurate, complete or up-to-date. If we make a correction and have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.
1.11 You may direct any queries in respect of your Personal Information in respect of the above to the Chief Data Officer of Incuna at cdo@incuna.asia. You can also contact Astellas Data Protection Officer at privacy.au@astellas.com. Once a complaint has been lodged, the Privacy Officer will respond to you as soon as possible.
1.12 Your Personal Information will be hosted on a server located in Australia and will not be transferred to any location outside of Australia.
1.13 We reserve the right to change the terms of this Privacy Policy from time to time. We will use our best endeavours to notify users of the App when we make material changes to our Privacy Policy.
This may include displaying a notification on our software through which we provide the App or via email notification.
This Privacy Policy was last updated on 25 March 2022.