Privacy notice

navify® My Care MOBILE APP PRIVACY NOTICE FOR USERS LOCATED IN THE UNITED STATES OF AMERICA

Effective Date. This Privacy Notice (“Notice”) is effective as of December 1, 2024.

Roche, including our Affiliates, is committed to protecting your Personal Information. This Notice, together with navify My Care Mobile App Terms and Conditions of Use (together – the “Terms”) outlines the types of Personal Information Roche may collect; the means by which Roche may collect, use, or share your Personal Information; steps Roche takes to protect your Personal Information; and choices you are provided with respect to the use of your Personal Information.

Please read this Privacy Notice carefully. We respect your privacy and we want you to understand how we manage the information you provide to us and the measures we take to protect it. By registering to use the navify My Care Mobile App (the “App”), you acknowledge that you have read, understood and agree to the App’s Privacy Notice, and that you consent to the collection, use, processing and disclosure of your Personal Information as outlined below and in compliance with the Terms and applicable laws and privacy regulations.

Please also review Roche’s US Supplemental Privacy Notice to understand what rights you may have under applicable US state privacy laws.

This Notice only applies to your use of the App. This Notice does not apply to any third party apps or websites linked to or accessible from the App. Roche is not responsible for the privacy practices, the content or any Processing activities of any third party sites or apps.

In order for you to use the App, we require certain Personal Information, as described below. Please note: if you choose not to provide us with your Personal Information, it will not be possible for you to use the App.

Definitions

“User” or “you” means you, the individual who is using the App.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including, but not limited to, your name, address, e-mail address, phone number or certain categories of sensitive personal information (such as health data you may choose to share with us).

“Processing” means any operation or set of operations which is performed on Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Roche Customer” means any institution, corporation or individual, which Roche conducts business with and which subscribed to use Roche’s navify Remote Patient Management solution to which this App is a component.

“Roche Group” means F. Hoffmann-La Roche AG, a Swiss multinational healthcare company, together with all the corporations through which it operates worldwide. Learn more about Roche Group and Roche Affiliates by visiting: Roche | Worldwide.

“Roche” or “we” or “us” means (i) when in relation to the App’s legal manufacturer: Roche Molecular Systems Inc.; 2881 Scott Blvd, Santa Clara, CA 95050; United States of America (the “Legal Manufacturer”); (ii) when in relation to the App’s enabler or distributor: a company-member of Roche Group other than the Legal Manufacturer that operates in the county where the App is made available to you (“Roche Affiliate”); and (iii) when in relation to Roche a service provider: Legal Manufacturer, Roche Affiliate and/or any other company-member of Roche Group that is providing services that are requested by you in relation to the App. This may include companies-members of Roche Group that are owned or controlled by the Legal Manufacturer, own or control Legal Manufacturer, or such that are owned or controlled by the ultimate parent company of Legal Manufacturer.

Why Does Roche Ask for My Personal Information? Roche needs to know some Personal Information about you in order to perform the services requested by you in our App.

What Personal Information Does Roche Collect? In order to facilitate your use of the App, Roche will require:

Your first and last name;
Your email address;
Your phone number;
Your date of birth;
Your IP address (for authentication, security and App health monitoring only);
Your device’s Universal Unique Identifier (UUID), assigned by your device manufacturer for device identification at the time of manufacturing (security and App health monitoring only); or
Limited personal and/or sensitive health information, such as your self-reported vital signs or medical history.

Legal Basis for Processing of Personal Information. Roche may process your Personal Information as directed by you or your healthcare provider (Roche Customer). Roche Customers enter into an agreement with Roche in order to enable your use of the App. Roche Customers will instruct Roche what Personal Information to Process on their behalf. Therefore, Personal Information that is Processed by Roche is Processed to facilitate your use of the App on behalf of and as requested by a Roche Customer that instructed you to download and use the App.

You may also download the App to use it on your own consistent with the Terms. In this case, Roche will process your Personal Information to perform a contract with you and to perform the services requested by you when you download and use the App, or otherwise take an action expressly permitted or authorized by you.

In addition, Roche may Process your Personal Information to facilitate Processing in our legitimate interests that is not overridden by your rights; or to comply with applicable law.

Does Roche Collect Any Non-Personal Information? Roche collects non-personal information to help improve our products and services, and for internal research or other business purposes (“Roche Purpose”). This may include your feedback, aggregated data, analytics (such as what brand, type and model of device you are using), and other non-personal information resulting from your use of the App. The non-personal information collected and used for Roche Purpose will not personally identify you.

How Does Roche Collect My Personal Information? You disclose your Personal Information to us via the App. Your healthcare provider may also disclose your personal information to Roche.

How Will Roche Use my Personal Information? Any Personal Information we collect and process on your behalf will be used solely to:

Facilitate your use of the App as requested by you or your healthcare provider.
Verify your identity and maintain your account, settings, and preferences.
Provide technical support when requested by you.
Collect feedback to improve the App.
Personalize content and communications about the App.
Monitor and improve operations, security practices, and algorithms.
Respond to legal proceedings and obligations.

Will Roche Use My Personal Information for Marketing Purposes? We will not use, sell or transfer your Personal Information for marketing purposes.

How Will Roche Share My Personal Information with Others?We do not sell your Personal Information. Roche will share your Personal Information with Roche Customers, service providers, for legal reasons, to support your use of the App, or upon your request.

Sharing with Your Healthcare Providers: Roche will share your Personal Information with your healthcare provider (Roche Customer) to facilitate the App’s functionality. Roche Customers will guide you on using the App and instruct Roche on processing your Personal Information.

Legal Reasons: Roche may share your Personal Information to comply with legal obligations, respond to government requests, enforce our Terms, prevent fraud, address security issues, defend legal claims, and conduct corporate audits or investigations.

Sharing with Roche’s Authorized Service Providers and/or Subprocessors: We rely on our authorized service providers and subprocessors to provide our services to you and to Roche Customers.

How Does Roche Protect My Personal Information? Roche uses reasonable physical, technical, and administrative safeguards (such as firewalls, encryption, identity management, and intrusion prevention and detection) to protect the information you share with us through the App from loss, misuse, or unauthorized disclosure. All data uploaded into the App is encrypted in transit and at rest. Roche cannot guarantee the absolute security of your Personal Information, as no data transmission over the Internet or data storage system is guaranteed to be 100% secure. We recommend that you take any available precautions to protect Personal Information you submit via the App. If you believe that your App account security has been compromised, please contact us immediately as detailed in the “Contact Us” section in this Privacy Notice.

For How Long Does Roche Keep My Personal Information? We will keep your Personal Information for as long as you continue to use the App and maintain a registered user account. We may retain your information longer if required by law for purposes such as legal compliance, accounting, or security audits.

Will Roche Transfer My Personal Information Across International Borders? Your Personal Information is Processed and stored in the United States of America. As permitted or required by local law, your Personal Information may be transferred to, Processed or stored in a country different from your country of origin. These countries may impose different privacy obligations than your country of origin. In transferring your Personal Information, we will rely on appropriate legal mechanisms to justify such transfer and ensure an adequate level of protection in accordance with all applicable laws.

What Rights Do I Have with Regards to My Personal Information? Roche enables you to access, control and delete your Personal Information. Please review Roche’s US Supplemental Privacy Notice to understand what rights you may have under applicable US state privacy laws.

Can Roche Make Changes to this Privacy Notice? We may change this Privacy Notice from time to time. When changes are made, the new Privacy Notice will be available to you via the App. We will provide you with notice via email if we make material changes to this Notice. If you do not agree to the changes after receiving notice of changes, you should stop using the App. Please regularly check the App to review the then-current Privacy Notice.

Important Note about Children’s Privacy. The App is not intended to be and may not be accessed or used by anyone who has not reached the age of majority in their location. If you are a parent or guardian and you become aware that your child has provided us with Personal Information, please contact us so that appropriate measures may be taken.

Your Privacy Related Requests. Your Personal Information is Processed by Roche in the App on behalf of and as requested by Roche Customers – individuals or legal entities that instructed you to download and use the App. To exercise your privacy rights, such as filing a complaint or opting out, contact the Roche Customer (e.g., your healthcare provider) who instructed you to use the App.. In the event you contact Roche directly for any of the above, Roche will promptly notify Roche Customer, and will reasonably assist them in executing your privacy related request.

Contact Us. If you have questions or comments about this Notice or about how your Personal Data is processed, or if you’d like to exercise any of your rights, please complete the form located here or, if you prefer, contact us as follows:

Email: [email protected]
Mail: F. Hoffmann-La Roche Ltd, Attn: Privacy Office, 9115 Hague Road, Indianapolis, IN 46256
Phone: (800) 975-7105

We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We will not discriminate against you for exercising any of the rights described above, although we may not be able to continue to provide you products and services or it may otherwise affect the way we are able to interact with you.

Please note that email communications are not always secure. Please do not include health information or other sensitive information in your email to us.