Your privacy is important to us. It is Nemo Healthcare B.V.'s policy to respect your privacy and comply with any applicable law and regulation regarding any information we may collect about you via our NemoRemote App and its associated services.
NemoRemote App, together with NemoRemote Link and Link Charger, form a NemoRemote system - a non-invasive and wireless medical device that accurately monitors fetal and maternal heart rate and uterine activity. The product is intended for use by patients in a home setting (prescribed by their healthcare professional) and for use in non-acute care settings in a midwifery practice or hospital by healthcare professionals.
In this Privacy Statement, you can read what type of data is collected by the NemoRemote App and how it is managed.
This policy is effective as of 28 March 2022.
Last updated: 28 March 2022
‘Personal Information’ means any information relating to an identified or identifiable natural person. An ‘identifiable natural person’ is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
'Sensitive Information' is a subset of Personal Information that is given a higher level of protection. Examples of Sensitive Information include information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information, or biometric information.
‘Anonymous data’ is data which cannot be related to an identified or identifiable natural person.
‘Pseudonymous data’ is data which can be related to an identified or identifiable natural person but only by using additional information.
'Automatically Collected Information’ refers to any information automatically obtained by the NemoRemote App during use.
'Voluntarily Provided Information’ refers to any information you knowingly and actively provide us when using the NemoRemote App and its associated services.
‘App Data’ refers to both the Voluntarily provided and Automatically collected information which is stored on the device by NemoRemote App.
‘Monitoring Data’ is a subset of Personal Information and consists of anonymous patient recordings collected and processed by the NemoRemote App, including:
‘Raw Data’ - a mixture of electrophysiological signals including maternal electrocardiogram (MECG), fetal electrocardiogram (FECG), electrohysterogram (EHG), and various noise sources
‘CTG Data’ – collection of Fetal Heart Rate (FHR), Maternal Heart Rate (MHR) and Uterine Activity (UA) values calculated from Raw data
‘Baby Movement Data’ – user-generated indication of moment(s) when baby movement was experienced by the user.
‘Log Data’ – NemoRemote App ‘event log’ consisting of performance and diagnostics data such application start/end time, state and parameter changes, status messages, technical errors and similar.
‘Device Identifier’ – a unique and permanent number assigned to each NemoRemote App installation.
‘Retrieving Data’ refers to the non-automated action of Nemo Healthcare retrieving App Data from the device.
‘Transferring Data’ refers to the automated action of the NemoRemote App transferring Monitoring Data to your Care giver.
‘Care giver’ refers to your midwifery practice or hospital.
Information We Collect
Automatically collected information: NemoRemote App collects Monitoring Data and Log Data during an active monitoring session. This data is anonymous and will remain on the device until it is manually deleted by your Care giver or by one of our service engineers.
Voluntarily provided information: NemoRemote App will collect Baby Movement Data when user manually provides it. This data is anonymous and will remain on the device until it is manually deleted by your Care giver or by one of our service engineers.
Transferring Data to your Care giver:
NemoRemote App automatically transfers your CTG Data and Baby Movement Data, as well as Device Identifier to your Care giver. Data is transferred via Internet encrypted. Your Care giver is responsible for coupling of the transferred data to your electronic patient record. This is achieved by means of the Device Identifier which is registered to an identifiable person by the Care giver at admittance - thus making the transferred data pseudonymous from the perspective of Care giver.
It is important to note that Device Identifier itself is not sufficient for identifying you as a person and that Nemo Healthcare does not collect nor has access to additional information which would allow such an identification, thus making the data anonymous from the perspective of Nemo Healthcare.
App Data stored on the device
NemoRemote App automatically stores your Monitoring Data, Log Data and Device Identifier on the device locally. App Data will remain on the device until it is removed by your Care giver or by one of our service engineers. Noted data does not contain any information that can be used by Nemo Healthcare, directly or indirectly, to identify you.
Retrieving Data by Nemo Healthcare:
In exceptional cases Nemo Healthcare may retrieve Monitoring and Log Data which is stored on the devices. When so, the data will be stored at Nemo Healthcare and used for the sole purpose of improving and developing Nemo Healthcare products. Noted data does not contain any information that can be used by Nemo Healthcare, directly or indirectly, to identify you.
Security of the collected data
App Data stored on the device does not contain any information that can be used by Nemo Healthcare or a third-party, other than your Care giver, to directly or indirectly identify you. As an additional measure of protection, stored Monitoring Data is encrypted.
When Nemo Healthcare retrieves App Data and stores it at Nemo Healthcare, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.
How Long We Keep the collected data
App Data stored on the device will remain there until it is removed by your Care giver or by one of our service engineers.
App Data that we retrieve for the purpose of product improvement and product development will be kept at Nemo Healthcare for an indefinite period of time.
We do not aim any of our products or services directly at children under the age of 13. NemoRemote App does not collect any information that can be used by Nemo Healthcare or a third-party, other than your Care giver, to directly or indirectly identify you.
Disclosure of Personal Information to Third Parties
The NemoRemote App transfers CTG Data, Baby Movement Data and the Device Identifier to your Care giver. Data transfer is encrypted and done via Internet. Your Care giver couples the transferred data to your electronic patient record, and therefore is responsible for protecting your privacy.
In case Nemo Healthcare retrieves your anonymous App Data, the data will be stored at Nemo Healthcare for the purpose of product improvement and product development and will NOT be disclosed to any other party.
Your Rights and Controlling Your Personal Information
If we receive non-anonymized Personal Information about you from a third party (e.g. your Care giver), we will anonymize the data/information on receipt immediately.
If you are a Care giver, we strongly request you NOT to provide us with Personal Information that discloses (directly or indirectly) the identity of your patient. (Clinical) information that is submitted to Nemo Healthcare (e.g. for example to substantiate a complaint or service request) should be anonymized.
Marketing permission: We will not use App Data for marketing purposes .
Access & Correction: App Data retrieved by Nemo Healthcare is considered anonymous. Therefore it is technically not possible to identify, access and correct “your” data stored at Nemo Healthcare (if any).
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and/or the promises we made in this privacy statement, you may submit a complaint. Please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include collected data, including anonymized App Data, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use aforementioned data according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Limits of Our Policy
The NemoRemote App transfers your CTG and Baby Movement Data as well as Device Identifier to your Care giver. Please be aware that we have no control over those receiving data systems, and cannot accept responsibility or liability for their respective privacy practices.
Changes to This Policy
For any questions or concerns regarding your privacy, please contact us using the following details: