Pacinity Platform Privacy Statement
Last updated: 10 October 2024
We respect your privacy
Transformative Insights Limited - company number 1009654 (“we”, “us”, “our”) is committed to protecting and respecting your privacy. Our contact details are set out at the end of this Privacy Statement.
This Privacy Statement sets out the basis on which we will collect, store, use and share your Personal Information on our Pacinity Platform (“Platform”). “Personal Information” is information and data we hold which is identifiable as being about you.
The particular instance of the Platform you have access to, is provided to you by one of our client organisations (“Tenant”). This can be your employer, a research institute, or another organisation providing you access. The Tenant instance contains one or more initiatives, studies, or groups (“Projects”) one or more of which you are enrolled in.
By providing us with Personal Information, you consent to the terms of this Privacy Statement and the types of disclosures covered by this Privacy Statement.
The Personal Information we collect about you
When you register an account and connect your wearable device to our Platform, we may collect the following Personal Information about you:
Your name.
Your email address.
Data that is collected by your wearable device and you have authorised us to access through the Terra API service when you registered your wearable device on the Platform.
Information about you that you provide to us by completing the Health Details form on the Platform.
Log data, which is information about your activity on our Platform such as when you login and logout, connect or disconnect your wearable device, when you make changes to your Personal Information, etc.
How we use your Personal Information
The purpose of collecting and using your Personal Information is to provide you with our services and to continuously improve our services to you. What we use your Personal Information for in relation to this purpose includes one or more of the following:
To contact you;
To identify you in our platform;
To set up and administer your account;
To provide you with personalised metrics and related information, insights, and recommendations you have requested from us when you accepted the invitation to enrol in a project that serves this use case on the Platform;
To provide the Tenant aggregated and non-identifiable information which you authorised us to provide the Tenant when you accepted the invitation to enrol in a Project that serves this use case on the Platform;
To provide the Tenant with identifiable wearable data (such as active minutes and step counts) which you authorised us to provide the Tenant when you accepted the invitation to enrol in a Project that serves this use case on the Platform;
To conduct research studies you registered and provided informed consent for;
Research and analysis, including evaluating and improving our models and services;
Protecting and enforcing our rights as part of our relationship with you;
Privacy management, cyber security, and information assurance;
Complying with applicable laws and regulations;
For any other purposes authorised by you.
If you do not provide us with your Personal Information, we will not be able to provide our services to you.
Storage of your Personal Information
We store your Personal Information electronically ourselves and with third parties that we contract to provide application and database hosting services. These databases are stored on servers located in New Zealand and overseas. We will act reasonably to ensure that your Personal Information is protected from unauthorised access, use, modification, or disclosure.
Wearable device information that we receive may be processed by or transferred between parties located in countries outside of New Zealand. These may include but are not limited to your wearable device provider and the Terra API service.
How long we keep your information
We will only keep your Personal Information for as long as we require it for the purpose for which it was collected. However, we may also be required, for example by law, to keep some of your Personal Information for longer periods of time.
In addition, we may retain your de-identified data for use in connection with research and analysis even though you cease to use our services and/or your account on the Platform is closed.
Disclosure of your Personal Information
We use your Personal Information for the purposes set out above in this Privacy Statement. As part of this use of your Personal Information, we may disclose your Personal Information to:
any of our employees, subcontractors, and third-party service providers insofar as reasonably necessary for the purposes set out in this policy;
the Tenant whose platform instance you are connected to, if you are enrolled in a Project that includes as its purpose to provide the Tenant with Personal Information;
others if we are required by law to do so.
We will not otherwise disclose your Personal Information unless we believe on reasonable grounds that you have provided your authorisation. However, you should be aware that we may be required to disclose your Personal Information without your consent if such disclosure is required by law.
If you no longer want us to disclose your Personal Information, you can ‘opt-out’ from the Projects you are enrolled in on our Platform, or close your account. Alternatively you can ask us to do this for you by emailing us at privacy@pacinity.com. When you ‘opt-out’ or close your account, we may be unable to provide you with our services.
We will not use your Personal Information for marketing or any other purpose, unless authorised by you through separate consent. We will also not make your Personal Information (in neither identifiable nor de-identified form) available to third parties undertaking research and analysis, unless you have authorised us to do so in writing.
Accessing and correcting your Personal Information
You may request access to the Personal Information we hold about you, or request that we update or correct any Personal Information we hold about you by setting out your request in writing and sending it to us at privacy@pacinity.com.
We will review your request as soon as reasonably practicable and in accordance with applicable laws. If we are unable to give you access to the information you have requested, we will give you reasons for this decision in accordance with the requirements of the Privacy Act 2020 and the Health Information Privacy Code 2020 when we respond to your request.
Change of ownership
If there is a change of ownership of all or a portion of our business, we reserve the right to transfer our databases, together with any Personal Information to the new owner so that the business can continue operations and provide our services to you.
Changes to this Privacy Statement
We reserve the right, at our sole discretion, to modify this Privacy Statement at any time. Changes will take effect immediately upon their posting on our website. We recommend you check our website from time to time to review our Privacy Statement. If we make material changes to the Privacy Statement, we will notify you via email that it has been updated.
Contact us
If you have any questions, comments or concerns about our Privacy Statement, please contact us at privacy@pacinity.com.