Way to Health

Privacy Policy for Research Involving Way to Drive

The research team at the University of Pennsylvania wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect

The research team at the University of Pennsylvania wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect:

Collectively, we refer to the Websites, the Apps and our Social Media Pages as the “Services”.

Personal Information

Personal Information” is information that identifies you as an individual or relates to an identifiable individual including, but not limited to:

Collection of Personal Information

We and our third-party service providers collect Personal Information in a variety of ways, including:

Through the Services

From Other Sources

If you disclose any Personal Information relating to other people to us or to our third-party service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our third-party service providers use Personal Information for legitimate business, research, and operational purposes including:

Meeting the aims and objectives of our research, such as enrolling you in a trial and registering for applicable accounts, as well as to analyze data collected and measure outcomes.

Providing the functionality of the Services and fulfilling your requests.

We will engage in these activities to manage our relationship with you and/or to comply with any legal obligation.

Providing you with our newsletter and/or other materials and facilitating social sharing

We will engage in this activity with your consent or where we have a legitimate interest.

Analysis of Personal Information for research and providing personalized services.

We will provide personalized services either with your consent or because we have a legitimate interest.

Aggregating and/or anonymizing Personal Information.

For our operational purposes.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

Disclosure of Personal Information

We may disclose Personal Information:

To our affiliates, owned or controlled by the research team for the purposes described in this Privacy Policy.

To our third-party services providers to facilitate services they provide to us.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

To comply with applicable law and regulations.

Other Information

Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual:

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

Collection of Other Information

We and our third-party service providers may collect Other Information in a variety of ways, including:

Through your browser or device:

Certain information is collected by most browsers or automatically through your device. We use this information to ensure that the Services function properly.

Through your use of the App

When you download and use the App, we and our third-party service providers may track and collect App usage data, which may include the following:

How We Use Data Collected through our Services

Using cookies

Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our third-party service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our programs, initiatives, offerings and services are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

Using technology to track use of services and improve the services

IP Address

Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.

Physical Location

We will collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We will record this information through the Way to Drive App and use your device’s physical location to collect relevant information for research and/or operational purposes. Your physical location data will only be recorded by the App when your device is moving more than five miles per hour (considered a driving trip event). We will be unable to enroll you in our research trials if you do not share your device’s physical location with us.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

Choices and Access

Your choices regarding our use and disclosure of your Personal Information

Access to, change of or deletion of your Personal Information

To the extent these rights are provided to you by applicable law, if you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, object to the processing of Personal Information or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another entity, please contact us at waytodrive@pennmedicine.upenn.edu. We will respond to your request consistent with applicable law.

Retention Period

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

Third-party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

Use of Services by Minors

The Services are not directed to individuals under the age of fourteen (14), and we do not knowingly collect Personal Information from individuals under 14.

Third-party Payment Service

We may use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.

Updates to this Privacy Policy

The “*Last Updated*” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contacting Us

The research team at the University of Pennsylvania is responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at waytodrive@pennmedicine.upenn.edu .

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

Additional Information

In accordance with applicable law, you may lodge a complaint with the relevant privacy or data protection regulatory authority.

LAST UPDATED: May 17, 2021