LOGEX / Brightfish Mobile App Privacy Policy
Effective Date: 12 December 2024
At LOGEX / Brightfish, we are committed to protecting your personal data and ensuring transparency about how we process information through our mobile applications. This Privacy Policy applies to all LOGEX mobile apps, including those used for completing Patient-Reported Outcome Measures (PROMs) and Patient-Reported Experience Measures (PREMs), whether accessed via anonymous QR code or through a registered account (e.g., email-based login).

1. Who We Are This mobile app is provided by:
LOGEX / Brightfish B.V.
Claude Debussylaan 82, 1088 MD Amsterdam, Netherlands
Chamber of Commerce (KvK): 64703033
Email: privacy@logex.com
Website: www.logex.com
Brightfish / LOGEX acts as the data processor for the processing activities described in this policy, on behalf of a hospital or research institution.

2. What Data We Collect Depending on how the app is used, we may collect the following types of data:
A. Anonymous Use (e.g. QR Code Access):
PROM/PREM survey responses
General usage data (e.g. time of completion, device type, app version)
Optional: Sensor data if explicitly enabled (e.g. step count, heart rate)
B. Account-Based Use (e.g. Email Login):
Name, email address, and login credentials
PROM/PREM survey responses linked to your account
User preferences and app settings
Optional: Lifestyle or health data if you choose to provide it
We do not collect GPS/location data or access your device’s contacts or photos unless explicitly described and consented to in-app.

3. Purpose and Legal Basis for Processing We process your data for the following purposes:
Delivering surveys and collecting PROMs/PREMs as part of healthcare, research, or quality monitoring
Supporting personalised follow-up or feedback (where applicable)
Improving app performance and usability
Complying with legal obligations or ethical research standards
Legal bases under the General Data Protection Regulation (GDPR) include:
Your consent (e.g. when you voluntarily submit data)
Performance of a contract (e.g. using the app to participate in a health program)
Legitimate interests (e.g. app analytics, system maintenance)

4. Who Has Access to Your Data Your data may be shared with:
The healthcare provider or institution inviting you to use the app (e.g. your hospital)
LOGEX’s internal teams responsible for app functionality and support
Trusted third-party processors (e.g. cloud hosting or analytics providers), bound by strict data protection agreements
We do not sell or share your personal data with advertisers or third-party marketing services.

5. Data Retention We retain your data only as long as necessary for the purpose it was collected:
For anonymous users: data is stored without identifying information and retained for statistical or research purposes
For registered users: data is retained for the duration of your account and/or project participation, unless otherwise required by law or contract

6. Your Rights Under the GDPR, you have the right to:
Access your personal data
Request correction or deletion of your data
Withdraw consent at any time
Object to or restrict processing
Lodge a complaint with your local data protection authority
To exercise these rights or request deletion of your account and associated data, contact us at: Email: privacy@logex.com

7. Security Brightfish / LOGEX uses industry-standard measures to protect your data, including encryption, pseudonymization, and access controls. Data collected through the app is securely stored in the European Economic Area (EEA) unless otherwise agreed upon with your healthcare provider.

8. Changes to This Policy We may update this Privacy Policy from time to time. Significant changes will be communicated within the app or via email if applicable.

9. Contact Us If you have questions or concerns about this policy or how your data is processed, contact our Data Protection Officer:
Email: privacy@logex.com
Phone: +31 20 215 7000
Postal: LOGEX International B.V., Claude Debussylaan 82, 1088 MD Amsterdam, Netherlands