Privacy Policy

1. General provisions

This Privacy Policy explains how the TaskMedAlert mobile application (“TaskMedAlert”, “the app”) processes information and in which cases personal data may be received and processed by DATSOM.

TaskMedAlert may be distributed in different versions with different sets of features.

Therefore, this Policy consists of:

• general provisions applicable to all versions of TaskMedAlert;
• separate sections describing the specific features of data processing in particular versions of the app.

The general provisions apply to all versions of TaskMedAlert unless the section for a particular version expressly states otherwise.

The section for a particular version supplements the general provisions and describes only the data-processing features that relate to that version.

If the manner in which personal data is processed changes, the relevant part of this Policy will be updated before the new processing begins, where required by applicable law.

2. Who is responsible for data processing

The controller responsible for personal data that DATSOM actually receives in connection with the use of TaskMedAlert is:

DATSOM BEZZUBENKO
Organization number: 938 320 551
Norway
Email: info@datsom.com

Users may contact this address with privacy questions and to exercise their rights regarding personal data held by DATSOM.

3. General principles of data processing

DATSOM follows the principles of lawfulness, transparency, purpose limitation, data minimization, storage limitation and security.

In particular:

• only data necessary for a specific stated purpose is processed;
• where possible, data is processed locally on the user’s device;
• personal data is not sold to third parties;
• data is not used for purposes incompatible with the purpose for which it was obtained;
• data is not stored longer than the established or reasonably necessary period;
• reasonable technical and organizational security measures are applied;
• information about data-processing practices is kept up to date.

4. Local data processing

The presence of information within TaskMedAlert does not mean that DATSOM receives that information.

Some data may be stored and processed exclusively on the user’s device.

If the section for the relevant version states that certain data is stored locally, DATSOM does not receive it automatically and does not have ordinary remote access to its contents.

The section for the relevant version of TaskMedAlert specifies which data remains local and which data may leave the device.

5. Transfer of information initiated by the user

Some TaskMedAlert features may allow the user to independently transfer information to DATSOM, another application, a service or a selected recipient.

If a transfer is performed only at the user’s initiative, this is stated in the section for the relevant version or feature.

After information is transferred to an independent third-party service, further processing of that information may be governed by the rules and privacy policy of the relevant service.

DATSOM does not control independent applications and services that the user selects to transfer information.

6. Third-party services

Google Play may independently process information related to downloading, installing, updating, licensing, security and use of the app in accordance with Google’s terms and privacy policy.

If other third-party services relevant to the processing of user data are used for the operation of a particular TaskMedAlert version or feature, this is stated in the relevant section of this Policy.

Third-party services that the user independently selects to transfer information may process data in accordance with their own rules and privacy policies.

7. Legal bases for processing

DATSOM processes personal data only where an applicable legal basis exists.

For ordinary personal data received through user enquiries, technical support or the feedback feature, the legal basis is DATSOM’s legitimate interest under Article 6(1)(f) of the GDPR.

The legitimate interest includes:

• responding to user enquiries;
• diagnosing technical problems;
• correcting errors;
• ensuring the security and stability of TaskMedAlert;
• improving the operation of the app.

When processing is based on legitimate interest, DATSOM takes into account the nature of the data, the necessity of the processing and the user’s rights and interests.

The user has the right to object to processing based on legitimate interest, subject to the conditions of the GDPR.

If processing is necessary for compliance with a legal obligation to which DATSOM is subject, the legal basis may be Article 6(1)(c) of the GDPR.

If another legal basis applies to specific processing, it is stated in the relevant section of this Policy.

8. Unsolicited medical and other sensitive data

The ordinary technical support or feedback feature of TaskMedAlert is not intended to collect medical data or other special categories of personal data.

DATSOM does not ask the user to provide the following through an ordinary enquiry:

• diagnoses;
• names of medications being taken;
• dosages;
• test results;
• medical documents;
• other medical or sensitive information.

Such information is not required to review an ordinary technical problem.

Users are advised not to include unnecessary medical or other sensitive information in the text of an enquiry and to check the contents of images and other attachments before sending them.

A user’s independent submission of such information does not mean that DATSOM requests it or intends to use it to process an ordinary enquiry.

If DATSOM discovers that a user has submitted medical data or other special categories of personal data that DATSOM did not request and that are not required to review the enquiry:

• such data is not used for advertising, profiling, user analytics or other additional purposes;
• unnecessary data, or the part of the enquiry containing it, is deleted without undue delay after it is identified;
• where necessary, the user may be asked to describe the problem again without sensitive information.

Such data is not retained for the ordinary retention period for enquiries.

An exception is possible only where retaining specific information is permitted by applicable law and is necessary to comply with a legal obligation or to establish, exercise or defend legal claims.

In that case, processing is carried out only to the minimum extent necessary and where an applicable legal basis exists, including the relevant condition under Article 9 of the GDPR where required.

9. Retention and deletion

Specific retention periods depend on the category of data and the manner in which it is processed.

For data that DATSOM actually receives, the retention period or the rule for determining it is stated in the section for the relevant version or feature.

DATSOM does not retain personal data longer than necessary for the stated purpose and the established retention period.

After the applicable period ends, data is deleted or anonymized unless further retention is required under applicable law or to establish, exercise or defend legal claims.

Data that is stored exclusively locally on the user’s device and has not been transferred to DATSOM is managed by the user.

10. Security

For local data, TaskMedAlert uses the storage and protection mechanisms provided by the device’s operating system.

For personal data actually received by DATSOM, reasonable technical and organizational safeguards are applied, taking into account the nature of the data and the risks of processing.

No method of storing or transmitting information can guarantee absolute security.

The user is also responsible for protecting their device, their accounts and information that they independently transfer to other persons or services.

11. User rights

With regard to personal data actually processed by DATSOM, the user may, where the relevant conditions of the GDPR are met:

• request information about the processing of their data;
• obtain access to their data;
• request correction of inaccurate data;
• request deletion of data;
• request restriction of processing;
• object to processing based on legitimate interest;
• exercise other rights provided by applicable data-protection law.

Requests may be sent to:

info@datsom.com

If data exists exclusively locally on the user’s device and has never been received by DATSOM, DATSOM cannot technically provide or delete such data on the user’s behalf.

In that case, the user manages it directly using TaskMedAlert or the operating system.

The user also has the right to lodge a complaint with the competent data-protection supervisory authority.

For DATSOM in Norway, that authority is Datatilsynet.

12. Automated decision-making and profiling

Unless the section for a particular version expressly states otherwise, DATSOM does not use the user’s personal data for automated decision-making that produces legal or similarly significant effects for the user.

Features specific to a particular version are stated in the relevant section of this Policy.

13. Children

TaskMedAlert is not specifically designed for children.

Data-processing practices are determined by the version of the app being used and the corresponding section of this Policy.

Parents and legal guardians are advised to supervise a child’s use of information about medications and other medical data where necessary.

Unnecessary medical or other sensitive data concerning a child should not be sent to DATSOM through the ordinary feedback feature.

If such data is received unnecessarily, the procedure described in section 8 of this Policy applies.

14. Medical warning

The user is responsible for the accuracy of medication names, dosages, schedules and other information entered.

A qualified healthcare professional should be consulted before starting, stopping or changing treatment.

Professional or emergency medical assistance should not be delayed because of information displayed by TaskMedAlert.

The operation of notifications and reminders may depend on device settings, permissions, power-saving features, device status, operating-system restrictions and other technical factors.

15. Changes to the Policy

The general provisions of this Policy apply to all versions of TaskMedAlert.

Separate sections may be used for particular versions of TaskMedAlert to describe data-processing features specific to the relevant version.

If a change concerns only a particular version, the general provisions and sections for other versions do not need to be restated.

If rules common to all versions of TaskMedAlert change, the relevant general part of the Policy is updated.

Changes affecting the processing of personal data are published before the relevant processing begins, where required by applicable law.

16. Contact

For questions about privacy, the processing of personal data and the exercise of user rights:

DATSOM BEZZUBENKO
Organization number: 938 320 551
Norway
Email: info@datsom.com

17. TaskMedAlert Free

The provisions of this section apply to the free version of the app — TaskMedAlert Free.

This section supplements the general provisions of this Policy.

17.1. Data stored locally

TaskMedAlert Free may locally process information that the user enters or creates in the app, including:

• medication names;
• dosages;
• comments and notes;
• schedules and reminder times;
• intake status and history;
• app settings;
• language settings;
• notification, sound and display settings.

Some of this information may constitute health data.

In TaskMedAlert Free, such data is stored locally on the user’s device.

DATSOM does not receive this data automatically.

17.2. Account and cloud storage

TaskMedAlert Free:

• does not require registration with DATSOM;
• does not create a DATSOM user account;
• does not upload user medication data to DATSOM servers;
• does not store user medication data in DATSOM cloud storage;
• does not synchronize user medication data with DATSOM servers.

17.3. Advertising, analytics and tracking

TaskMedAlert Free contains no advertising.

TaskMedAlert Free does not use advertising profiling of the user.

TaskMedAlert Free does not use third-party behavioral analytics to track the user’s actions in the app.

DATSOM does not automatically receive user data through advertising or third-party analytics SDKs.

17.4. Local diagnostic journal

To diagnose the operation of reminders and technical errors, TaskMedAlert Free creates a local diagnostic journal.

The journal:

• is stored on the user’s device;
• contains records covering no more than the last 24 hours;
• is limited to a maximum size of 5 MB;
• automatically deletes the oldest records when the established limits are reached;
• is not sent to DATSOM automatically.

The journal is intended for technical diagnostics.

It may contain:

• technical event codes;
• timestamps;
• technical statuses;
• error codes;
• technical events related to the scheduling, delivery and processing of reminders.

The diagnostic journal is not intended to store:

• medication names;
• dosages;
• user comments;
• user notes;
• free-form user text.

17.5. Feedback

TaskMedAlert Free includes an optional feedback feature.

The user may:

• select an enquiry category;
• optionally write a description;
• optionally select up to three images.

To send an enquiry, TaskMedAlert Free prepares an email addressed to:

info@datsom.com

and opens the system email application selected by the user.

TaskMedAlert Free does not send the enquiry itself in the background.

DATSOM receives the email only after the user sends it through the selected email application.

The prepared enquiry may contain:

• the selected enquiry category;
• optional text written by the user;
• technical information about the app and device;
• a diagnostic report;
• up to three images selected by the user.

The user can review the technical information before proceeding to the email application.

Images are added only after the user independently selects them.

17.6. Technical information in feedback

Technical information may include:

• app version;
• app build number;
• device manufacturer;
• device model;
• Android version;
• Android API version;
• screen resolution;
• screen density;
• app language;
• system language;
• time zone;
• report generation time;
• notification permission status;
• exact alarm capability status;
• aggregated notification channel status;
• battery optimization status;
• operating-system build information.

Technical information is used for:

• handling the user’s enquiry;
• diagnosing the technical problem;
• correcting errors;
• ensuring the stable operation of TaskMedAlert.

TaskMedAlert Free does not intentionally add the following to the technical information:

• medication names;
• dosages;
• comments;
• notes;
• free-form user text from medication data.

17.7. Images in feedback

The user may voluntarily select up to three images for an enquiry.

TaskMedAlert Free uses the Android system image picker to select images.

Images are not attached without action by the user.

Users are advised to check the selected images before sending and not to send unnecessary medical, personal or other sensitive data.

If such data is accidentally received by DATSOM and is not required to review the enquiry, section 8 of this Policy applies.

17.8. Email service

After the prepared email is passed to the system email application, it is subsequently sent by the email service selected by the user, such as Gmail, Outlook or another email provider.

The selected service may process:

• the user’s email address;
• information about the user’s email account;
• the contents of the email;
• attachments;
• technical delivery information.

Such processing is carried out in accordance with the rules and privacy policy of the email service selected by the user.

DATSOM does not select or control the user’s email provider.

17.9. Feedback retention period

Ordinary feedback emails and related technical attachments are retained by DATSOM for no longer than 12 months after the last interaction concerning the relevant enquiry.

They are then deleted unless further retention is required:

• for the continued review of the enquiry;
• to comply with an applicable legal obligation;
• to establish, exercise or defend legal claims.

Unnecessary medical data or other special categories of personal data accidentally received through an enquiry are not intended to be retained for this twelve-month period.

The procedure established in section 8 of this Policy applies to them.

17.10. Local storage and deletion

TaskMedAlert Free user data remains locally on the device until the user deletes the relevant data using the app, clears the app data using Android or uninstalls the app.

Because TaskMedAlert Free does not have a DATSOM user account and does not store user medication data in DATSOM cloud storage, DATSOM does not have a server copy of this local data that it could delete at the user’s request.

17.11. Android backup and transfer between devices

Cloud backup of the TaskMedAlert Free user database through Android Auto Backup is disabled.

TaskMedAlert Free does not use Android Auto Backup to send the user’s medication database to cloud backup storage.

When another Android device is configured, the operating system itself or the device manufacturer may offer the user the option to transfer some local data directly between devices.

Such a transfer:

• depends on Android and the device manufacturer;
• is initiated or authorized by the user;
• is not a transfer of data to DATSOM;
• is not controlled by DATSOM.

DATSOM does not receive data transferred directly between devices in this manner.

17.12. Android permissions and system features

Depending on the Android version and the features used by the user, TaskMedAlert Free may use:

• notification permission — to display reminders;
• system mechanisms for exact alarms and scheduling — to deliver reminders at the selected time;
• the system sound picker — to select a reminder sound;
• local app storage — to store local data and settings;
• the system image picker — when the user independently selects images for feedback.

These capabilities are used only for the corresponding app features.

17.13. What DATSOM does not receive automatically in TaskMedAlert Free

During ordinary use of TaskMedAlert Free, DATSOM does not automatically receive:

• the user’s medication names;
• dosages;
• comments and notes;
• intake schedules;
• intake history;
• the contents of the intake list;
• the user’s medical records;
• the user’s photographs and images;
• the user’s contacts;
• the user’s precise or approximate location;
• user data for advertising profiling.

Information may be transferred to DATSOM only in the cases expressly described in this Policy, where the user independently initiates the relevant action.