When you engage our professional services you supply us with a range of information about yourself. This Privacy Notice explains the types of personal data we may collect about you when you have contact with us and use our services. It explains how we will store and handle your personal information data, and how we will keep it safe. There is a lot of information here because you should be fully informed about your rights, and Bipolar Buddy want to ensure that your right to remain in control of your personal data is fully protected. We hope that what follows will answer any questions you may have but if not, please get in touch with us. We will update this Privacy Notice from time to time. We will notify you of any significant changes, but you can visit our website and check the most up-to-date version whenever you wish.

 

Who are we?

Bipolar Buddy was founded in 2021. Our mission is to help patients with bipolar disorder achieve and sustain remission using artificial intelligence and machine learning to support mood tracking and pattern recognition to discover underlying causes of mood changes. When we collect, store and process personal data we are a ‘data controller’.

Some key facts about the law on data protection

Consent

We must obtain your consent to collect and process information (data) about you. Whenever we collect your personal data, we will always make clear to you which data is necessary so that we may make our professional services available to you.

Legitimate interest

We collect and process your data in order to further our legitimate interests in ways which are reasonable and necessary to conduct our business. For example, we may use post or electronic means to remain in contact with you. To do this, we need to know your physical address or your electronic address. We would not collect, store or process personal data would in any way which would be detrimental to your rights, freedom or interests.

Contractual obligations

We may collect and process your personal data to meet contractual obligations.

Legal requirements

The law may require that we collect and process your data. For example, we may have to do this to comply with regulations on money laundering or to prevent fraud or other criminal activity. In such circumstances we may be bound by law to pass your data to legitimate authorities.

Some general points

When you engage our professional services and/or supply your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. When you use our services, you are giving your consent to us to transfer and disclose your personal data outside the UK (or outside your country of residence, if that is not the UK) for normal legitimate professional purposes. Third parties may be subject to different data protection laws from those which apply in the UK or in your country of residence. Bipolar Buddy cannot ensure in all cases that overseas recipients of your personal data will comply with the data protection laws of the UK or your country of residence.

What types of personal data do we collect and process?

As you might expect, we record information which allows us to identify you: your name, date of birth, gender, home and work/business addresses, email addresses and telephone numbers. We keep details of your professional dealings with us. For example, we would make a record of our interviews, conversations and briefings with you, in writing or electronically, as well as any complaints lodged by you. We make and keep copies of documents provided by you to prove your age, identity, nationality, immigration status in the UK or other countries, where the law requires this. Such documents would include passports and drivers’ licences. We may need to record bank account, debit and credit card information when clients are paying for our services. Your image may be recorded by still photography or video by CCTV security systems when you visit our place of business. We may record your social media username, if you interact with us through such media channels. We may combine any personal data that we collect directly from you with other data that we obtain from third parties to whom you have given your consent to pass that data onto us.

When do we collect your personal

Whenever you contact us for information and/or to engage our professional services whether by telephone, post, email, or through our website or on social media. When you contact us by any means with an enquiry or a complaint. When you make any kind of appointment to meet with us. When you fill in any forms, Bipolar Buddy may collect your personal data. When you comment on or review our professional services. Any individual may access personal data related to them, including opinions. If your comment or review is about Bipolar Buddy or an employee who provided a service, it may be passed on to them if requested. When you have given permission to a third party to share with us the information they hold about you. We collect data from publicly available sources when you have given your consent to share information or where the information is made public as a matter of law.When you enter our premises we may operate CCTV systems for the security of both clients and staff of Bipolar Buddy. These systems may record your image during your visit.

Protecting your data

Bipolar Buddy take our responsibility for the security of your personal data very seriously. We take measures to ensure the physical security of our information technology equipment, such as computers, against theft. We protect data on such devices from unauthorized access by using passwords and encryption and security software. We follow recommended protocols for good online security and we review these on a regular basis.

Sharing your data

We may share your personal data with trusted third parties. For example, when we use delivery services; to prevent fraud and other crimes; to deal with your comments or complaints. We apply strict policies of compliance with those trusted third parties to keep your data safe and protect your privacy:

  • We provide only the information they need to perform their specific services.
  • Third parties may use your data solely for the precise purposes we specify in our contract with them.
  •  If we stop using their services, your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work include:

  • IT companies who support our business systems.
  • Operational and partner companies such as NHS England; Scotland and Wales etc….
  • If we share your data with third parties for their own purposes, we will only do this in very specific circumstances, for example, to prevent fraud, we may share information about potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
  • We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our clients into consideration. For further information please contact our Data Protection officer or Bipolar
    Buddy CDO/CTO or CEO..

Transfer of data

Where we need to share your personal data with third parties, such as authorities outside the European Economic Area (EEA), we will take all reasonable steps, as required by UK data protection laws, to ensure your data is accorded the same protection as if it were being processed inside the EEA.

How long do we retain personal data?

We retain personal data only as long as it is needed by us either (a) to serve our clients or (b) to meet regulatory requirements. Once data is no longer needed it is securely stored or destroyed.

Your rights

You may withdraw your consent to our processing of your personal data at any time. You can correct your personal information when it is found to be wrong, when it has become out of date or if it is incomplete. You have the right to be supplied with a copy of all personal information about you, held by us. To keep your personal data safe, we will ask you to verify your identity. If a third party requests data on your behalf, we will require proof that they are acting with your permission. The data will be supplied within a reasonable time following your request for the information. You will be charged for the copy of your data only in those cases where Bipolar Buddy incurs legitimate costs in supplying the information.

To ask for a copy of your personal information held by us, please contact our Data Protection Officer. If, for any reason, we decline your request we will explain to you our reasons. If you are unhappy about any aspect of our use of your personal data, you have the right to complain to the Information Commissioner’s Office (ICO). The telephone number is 0303 123 1113. The ICO website is at www.ico.org.uk If your country of normal residence is not the UK, you may be able to complain to the data protection authorities in that country.

Bipolar Buddy’s data protection officer (DPO) is Raymond Hounon, the Bipolar Buddy chief
technology officer

The data provided is being used to improve our artificial intelligence and machine learning
algorithm, in order to create more accurate predictions of crisis moments. This is all in an effort by
Bipolar Buddy to support our users to achieve remission.

The user is always able to opt out of each processing activity and any personal identifiable
information or GDPR related data can be deleted from our system completely. Moreover, when
signing up on onboarding users have to give consent to offer their data.

Data will not be shared without user consent. No personal identifiable data is shared without user
consent.

The data collected by the app is stored in the Microsoft Azure and as per the Microsoft data
processing agreement (please see: DPIA Azure for the GDPR – Microsoft GDPR | Microsoft Docs).
Data is stored by Microsoft in the Online Service in a limited function account after 90 days after
expiration or termination of Customer’s subscription so that customer may extract the data.
Microsoft complies with strict security standards and industry-leading data protection methodology.
Microsoft is continually improving its systems to deal with new threats. More information regarding
cloud governance and privacy practices is available at Trust Centre’s Cloud Governance and Privacy
page: https://www.microsoft.com/trustcenter/guidance/ensure-compliance.

User data is encrypted between device and external host storage. We follow the GDPR rules (please
see: DPIA Azure for the GDPR – Microsoft GDPR | Microsoft Docs).

The data is destroyed upon request. The expiration period will be within 90 days from the point of
requesting us to delete your data. We will confirm consent every 6 months, the retention period is
done as per the GDPR requirements and will last a period of 90 days.
Users can report if a child accesses the app and provides personal data without parental consent and
this data will be deleted.
This privacy policy does not apply to third party links. Users should consult the third party’s policy.
Users can make further inquiries about privacy policy by reaching out to info@bipolarbuddy.co.uk. Bipolar Buddy uses two-factor authentication and data encryption in our database. We are using all
of the security measures of the Azure platform to protect user data on the app. There are also email
and password logins to authenticate that the user is you.

GDPR

The app is compliant with GDPR 2018.
The developer’s intent is to ensure data minimization principles are met.
If the purpose of data collection changes, the user will be informed and consent re-obtained.
Users have the right to request that their personal data be deleted or restricted.
Users have the right to object to the processing and portability of their data.
Users have a right to request not to be subject to decision based solely on automated processing,
including profiling.
Users can exercise their rights and will receive a response within 2 months. The contact details of
our developer are vipul@bipolarbuddy.co.uk, or the user can reach out via info@bipolarbuddy.co.uk
and the issue will be forwarded on to our primary developer. Vipul has a strong commitment to
addressing user support issues, and will respond within 1 week and eradicate the reported bugs and
faults within 3 weeks.
Professional Assurance
A qualified professional was involved in the development of this app. The lead developer was Aditya
Swami and his experience entails:

  • 12 years of experience
  • 2019 is the date of incorporation
  • 12 years of qualification
  • Bachelors in engineering, Pune University

The app has been shared with employees at Microsoft for testing.
Relevant healthcare professionals; Dr. Andy Zamar and Dr. Amrita Varanasi have provided input
during the development of this app as medical advisors and they positively support the development
of this app’s methodology. Bipolar Buddy is a part of Health Innovation Manchester cohort.
The information, recommendations in the app have come from online research and the testimonials
of Dr. Andy Zamar of the London Psychiatry Centre and Dr. Varanasi who is an NHS consultant
psychiatrist.

Risk Management Process

Our risk management process involves testing the app prior to posting the app on the app store and
requesting feedback from our initial user base in case of any negative repercussions.
Testing procedure has been with 100 people and we requested feedback. So far there has been no
negative emotional impact on any of our users. We are seeing positive returns on how users are
managing their activity. A trend is showing that they are improving every day in terms of their
habits; allowing them to have a more balanced, healthy and happy lifestyle.
The risks associated with using the app are anticipatory anxiety and stress due to predictions.
Anxiety from missing input opportunities, however, so far we have not seen any of this feedback.
The app has no drastic results in terms of our recommendations. The app takes care of making sure
that there are no dramatic mood recommendations so that the user is alarmed in any way. Episodes
are in no way caused by the app as the app simply works as a monitoring tool for the management
of bipolar disorder.
Our clinical safety officer is Dr. Amrita Varanasi, an NHS Consultant Psychiatrist.

Usability and Accessibility

User feedback was collected during design/development phases.
Users were involved in testing the app. 70 users tested the app. The results of our initial surveys are
as follows:

Usefulness – How useful do you think Bipolar Buddy is?

  • 10/14 (~71.4%) of users think that Bipolar Buddy is useful
  •  6/14 (~42.8%) of users think that Bipolar Buddy is very useful
  •  4/14 (~28.5%) of users do not think that Bipolar Buddy is very useful

Users’ Need for Bipolar Buddy – How much do you need Bipolar Buddy?

  • 10/14 (~71.4%) of users feel the need to use Bipolar Buddy
  •  6/14 (~42.8%) of users feel a higher level of need to use Bipolar Buddy
  • 4/14 (~28.5%) of users do not feel such a high level of need for Bipolar Buddy

 

 

Ease of Use – How easy is it to use Bipolar Buddy?

  • 8/14 (~57.1%) of users think Bipolar Buddy is easy to use
  • 6/14 (~42.8%) of users think that Bipolar Buddy is very easy to use
  • 6/14 (~42.8%) of users find more difficulty in using Bipolar Buddy
    Initial Overall Impression – When you first used the product, what was your overall
    impression of it?
  • 4/14 (~28.5%) of users had a positive initial impression of Bipolar Buddy
  •  11/14 (~78.6%) of users had an okay/average initial impression of Bipolar Buddy
  • 3/14 (~21.4%) of users did not have such a positive initial impression of Bipolar
    Buddy
    Likeliness to Recommend – How likely are you to recommend Bipolar Buddy to
    someone you know?
  • 9/14 (~64.3%) of users will recommend Bipolar Buddy to others
  • 6/14 (~42.8%) of users will strongly recommend Bipolar Buddy to others
  • 5/14 (~35.7%) of users will not strongly recommend Bipolar Buddy to others
    Importance of Self-Management of Bipolar Disorder – How important is it for you to
    manage bipolar by yourself?
  • 13/14 (~92.9%) of users feel strong importance in managing Bipolar Disorder by
    themselves
  • 1/14 (7.1%) of users do not feel the importance in managing Bipolar Disorder by
    themselves