Privacy Statement for m-Path Sense app users

KU LEUVEN R&D thinks your privacy and the protection of your personal data are important.

This Privacy Statement intends to provide you with clear and transparent information on how we deal with your personal data. We treat your personal data with care and we only process these in compliance with the applicable legislation, including the General Data Protection Regulation.

In the framework of the provision of the m-Pathapplication, we process the following personal data about you:

• your name and surname, or your alias,
• your IP address,
• your time zone,
• The type and operating system of your phone
• The version of the app you are using
• Data on your use of the app and possible crashes of the app
• App usage activity and list of installed apps.
• Raw sensor data: Accelerometer, gyroscope, and light sensor.
• Device information: Manufacturer, device model, type of operating system, etc. No unique device ID is gathered.
• Screen activity: Screen on, lock, and unlock events.
• Battery level (%) and status.
• Available working memory.
• Bluetooth, Wi-Fi and connectivity information. Bluetooth and Wi-Fi names and IDs are anonymised via a one-way cryptographic hash and therefore unreadable.
• Mobility information: Time spent at home, public places and distance travelled, and GPS coordinates.
• Physical activity information about activities of the user such as running, walking, etc.
• Step count (pedometer).
• Environment noise (decibel) via the microphone. This is processed directly in the app so that no audio data is saved.
• Call and text activity. Phone numbers, names, and texts are all anonymised via a one way cryptographic hash and therefore unreadable.
• Calendar information. Event title, description, and attendees are all anonymised via a one way cryptographic hash and therefore unreadable.
• Information about current weather situation and air quality (online service using participants’ location).

We process your personal data for the purpose of providing you with a license to our software and services, and for updating you on any new releases of the software or changes in the terms of the license agreement. Your practitioner shall inform you about the processing of your responses to the questions they created for you. If your practitioner has not given you clear and transparent information on the processing of your responses, you have the right to request such information from them.

If you agree, we additionally process data relating to your use of the software using Google Analytics for Firebase for the purpose of producing usage statistics and improving the software. Your consent to processing of data relating to your use of the software can be withdrawn at any time. We will not transfer your personal data to any third party without your written consent. We do not provide your personal data to parties outside of the European Union.

Your personal data shall be kept confidential and KU LEUVEN R&D provides all reasonable physical, electronic, and procedural safeguards to protect your personal data. We take all appropriate measures to safeguard and prevent unauthorised access to your personal data, including appropriate identity management measures, pseudonymisation and anonymization where possible, encryption where needed, informing and training our employees, and regular monitoring and evaluation of our security measures.

We shall store and process your personal data no longer than reasonably required by business necessity to meet the purposes for which your personal data were collected.

You have the right to contact us to request access to your personal data or to request correction of inaccurate data or completion of incomplete data. In accordance with the conditions of applicable law, you may object to our processing of your personal data and request that we delete your personal data or restrict processing of your personal data when there is no longer a legitimate purpose for doing so. You can also delete the data in the app yourself. For any data relating to your use of the software using Google Analytics for Firebase, you can always withdraw your consent.  You may make any of these requests by contacting us at: www.m-Path@kuleuven.be. We ask you to include a copy of your identity card (removing or hiding the photograph) in the request so that we can verify your identity.

If you have a complaint about our processing of your data or the exercise of your rights, you can contact us directly, but you also have the right to file a complaint with the Data Protection Authority or the competent court.

Any changes to this Privacy Statement will be announced on this website. The last  version dates from 8 April 2020.

If you want to know more about KU LEUVEN R&D’s privacy policy, go to https://admin.kuleuven.be/privacy/en.