Project Notebook Privacy Policy

Effective Date: Jan 22, 2019, Version 1.0

Since Project Notebook was founded in 2017, we’ve advocated that you own your own data, that you should be able to access it whenever and however you want, and that you should be able to share it however you see fit. In 2019, we feel more strongly about these tenets than ever. As Project Notebook has grown, we’ve added new features that make it easier for clinicians and researchers to make accounts that store data on behalf of their patients and study participants. Please read our Privacy Policy to understand how you can control and manage your data and the choices you have. It describes the types of information we collect from PwD, Care Team Members, Clinicians, Researchers and casual site visitors, how we use it, how we protect it, and how we restrict its disclosure. This Privacy Policy is intended to comply with all applicable laws and regulations, including but not limited to the General Data Protection Regulation (“GDPR”) of the European Union.

You may use the Project Notebook website without sharing any of your personal information with us. However, if you choose to use Project Notebook’s services, it will become necessary for Project Notebook to create an account for you and collect and process information about you. If you use any of the Project Notebook Apps, we will need to process and use the personal information you and members of your Care Team provide in order to provide the services of the Project Notebook Apps. The Project Notebook Apps will not function without that information.

The privacy and security of your information is important to us. This privacy policy (“Privacy Policy”) describes how Project Notebook Project (“Project Notebook,” “us,” or “we”) collects, uses, processes, and discloses information in connection with our software applications, such as Project Notebook for web, Project Notebook for mobile, and the Project Notebook Uploader, together with any other applications developed and/or distributed by Project Notebook (the “Project Notebook Apps”), including storage and retrieval of information by the Project Notebook Apps on or through our hosted cloud platform (the “Project Notebook Platform”). We collect information from the people who use the Project Notebook Apps to help manage their Cancer (“Data Owners,” the person with Cancer or the parent/guardian of one), from the people with whom the Data Owner chooses to share that information (“Care Team Members”), from doctors, healthcare professionals, and other clinicians who may use the Project Notebook Apps to review information for people under their care (“Clinicians”) and from researchers who collect information from study participants for research purposes through the Project Notebook Apps or Project Notebook Platform (“Researchers”). Data Owners, Care Team Members, Clinicians and Researchers may collectively be referred to herein as “Users” (or singularly, a “User”).

By using the Project Notebook Apps, you agree to be bound by this Privacy Policy, as well as our Terms of Use, which are incorporated herein by reference. Please read this entire Privacy Policy and the Terms of Use. If you don’t agree with the terms of this Privacy Policy or the Terms of Use, please don’t use the Project Notebook Apps or other applications that access your Project Notebook account. This Privacy Policy applies to Project Notebook’s treatment of “personal information,” which is information that directly or indirectly uniquely identifies a Data Owner, Care Team Member, Clinician or Researcher by reference to an identifier such as a name, identification number, location data, online identifier, or another factor specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual. This Privacy Policy therefore applies to health and other personal information, and the information, notes, and files Data Owners, any of a Data Owner’s Care Team Members, or Clinicians or Researchers upload, store, and manage using the Project Notebook Apps. This Privacy Policy does not apply to the practices of companies that Project Notebook does not own or control, or to individuals who Project Notebook does not employ or manage.

BY USING ANY OF THE Project Notebook APPS YOU AGREE TO THE COLLECTION, USE, AND DISCLOSURE OF INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU ARE A RESIDENT OF THE EUROPEAN UNION, WE WILL OBTAIN YOUR EXPLICIT CONSENT TO COLLECT AND PROCESS YOUR INFORMATION.

As this Privacy Policy explains, Project Notebook is responsible for determining the purposes and means for the handling and processing of personal information subject to this Privacy Policy. Project Notebook is the “controller” of that information for purposes of compliance with the GDPR. Project Notebook is located and may be contacted at:

Project Notebook
317 W Portal Ave, Unit# 27449
San Francisco, CA 94127
Attn: Privacy Officer
Telephone: 650-741-4956
E-Mail: info@projectnotebook.org

Project Notebook’s Privacy Official serves as our data protection officer. Any Data Owner, Care Team Member, Clinician or Researcher, or any other data subject, may contact the Privacy Official directly with questions, complaints, or suggestions concerning privacy or data protection, at the following address:

Bharat Welingkar
Project Notebook

Telephone:  650-741-4956
E-Mail:  privacy@projectnotebook.org

As our services expand, we will evaluate our policies and practices and occasionally implement changes and refinements. If we make a change to this Privacy Policy that we determine, in our sole discretion, is material, we will endeavor to notify you (for example, by email to the email address in your Project Notebook account) prior to the changes becoming effective. We will post all revised or new Privacy Policies on the Project Notebook website at https://projectnotebook.org/legal, and indicate the date it was last revised.

Project Notebook may treat the information of Data Owners, Care Team Members, Clinicians and Researchers differently. For this reason, this Privacy Policy has separate sections with information specific to Data Owners, to Care Team Members, to Clinicians and to Researchers, and a section that applies to everyone. To learn more, please review the following:

1. Information for Data Owners

We collect health and other information from you as a Data Owner so that we can show it to you in useful ways within the Project Notebook Apps. You may choose to share your health information with others and with applications that connect to the Project Notebook Apps or the Project Notebook Platform.

This section of the Privacy Policy describes what we do with Data Owner information, including but not limited to health information, and is guided by the following principles:

Frequently Asked Questions for Data Owners

1.1 What Data Owner information does Project Notebook collect and for what purposes?

1.1.1 Registration and Contact Information

To register as a Data Owner for a Project Notebook account, you must provide your email address and create a password. You use your email address and password to log in to your account. We will also collect contact information, such as your name, address, phone number, and certain information that does not itself directly identify you, such as your IP address. An IP address is a number assigned to you by your Internet service provider so you can access the Internet. Although we do receive IP addresses, we do not use them to identify you personally or disclose them to others.

We will use this information to: deliver, administer and improve the Project Notebook Apps; provide customer service; improve and personalize your experience; better understand your needs; fulfill requests you make; deliver special announcements and updates about the Project Notebook Apps; and contact you about any of the above as well as any changes to or notifications regarding your Project Notebook account.

1.1.2 Other Information You Provide to Us

We also collect health and other information you provide to us through the Project Notebook Apps. This may include your gender, age and birth date, weight, height, treatment and diagnosis information, health and well-being related information (including diet and activity information), information identifying the Cancer monitoring and treatment devices you use, and data you upload from your Cancer monitoring and treatment devices using Project Notebook Uploader, other Project Notebook Apps or through third-party applications that connect to the Project Notebook Platform.

We use the information you provide to us to deliver, administer, and improve the Project Notebook Apps. We need this information to provide the visualization, data analysis, and other features available to you through the Project Notebook Apps, which are also available to any of your Care Team Members. As we add new Project Notebook features for Data Owners, we may, if necessary, use your information to provide those features to you. When you seek support from us, the individual(s) providing you with support may need to access your information in order to identify the problem you are seeking support for, though your information will only be used to help provide you with support.

With your permission, and only with your explicit consent, we may also provide your health information and internal, diagnostic data from your Cancer device to the maker of that device, include your information in a research database, or share your information with third-party applications that you choose to connect with.

With your permission, and only with your explicit consent, we may also use your personal information that you provide to us or that we obtain from third parties to provide you with periodic emails, newsletters or mailings, with information on Project Notebook’s or our business partners’ products and services or other informational material we believe may be of interest to you. You have the option to decline these communications at any time by following the instructions below.

1.1.3 Third-Party Applications

You may have the option to link or connect Project Notebook Apps or the information collected with Project Notebook Apps with certain third-party applications. We will not share the information in your Project Notebook account with a third-party application without your explicit consent.

1.1.4 Study Management for Academic and Clinical Research

You may be asked to participate in academic, clinical, commercial or other research studies, either by Project Notebook or by entities performing research. You are under no obligation to participate in this research. If you do agree to participate, you will be asked to give us explicit consent to link your Project Notebook account to the study coordination account, or to provide a unique identifier that will allow the researcher or institution to link other personally identifiable information to your Project Notebook information. Only you can agree to this linkage with other information or databases. Project Notebook will not link the information in your Project Notebook account for academic, clinical, commercial or other research studies without your explicit consent. If you agree to participate in a research study, the person or organization conducting the study may require you to sign a written consent to participate in the study, which may include terms and conditions that apply to the research study and are different from those of this Privacy Policy.

1.2 What choices do Data Owners have?

Under the Terms of Use, Data Owners own the health and other personal information, data, notes, and files that Data Owners upload, store, and manage using the Project Notebook Apps or that are added by their Care Team Members. This means that you as a Data Owner decide who has access to the information in your Project Notebook account. You also have full control to edit permissions of Care Team Members, alter some types of information, export your information, or cancel your account and delete the information in that account from Project Notebook’s systems.

1.2.1 Care Team Access

You can grant access to your Project Notebook account to health care professionals, family, friends, or anyone else, creating what we call a Care Team. The Care Team Members to whom you provide access will be able to view and comment on the health and other information in your account. Only if you grant them permission will Care Team Members be able to upload information to your account or, if applicable, edit information in your account. Data Owners own all content in their Project Notebook accounts added or altered by their Care Team Members.

1.2.2 Custodial Accounts

A Clinician such as your doctor or other health care provider, or a Researcher conducting a study in which you participate, may establish an account to store information about you in Project Notebook. That Clinician or Researcher may invite you to open a Project Notebook account. If you accept that invitation, you will become a Data Owner and will have control of all the information associated with that account, which will be your Project Notebook account. When you open the account, the Clinician or Researcher who invited you to open the account will automatically be a member of your Care Team. You may remove the Clinician or Researcher from your Care Team at any time.

If your Clinician or a Researcher told you to expect such an invitation and you did not receive it, please contact that Clinician or Researcher and ask them to verify your email address and re-send the invitation.

If a Clinician or Researcher who uses Project Notebook to store information about you does not invite you to open an account, or if you decide not to do so, then you will not have control of the information associated with that account and this section of the Privacy Policy will not apply to you or to that information.

1.2.3 Options for Sharing Information with Device Makers

You may have the option of granting the maker of your Cancer monitoring or treatment device with access to the information you upload to the Project Notebook Platform. Providing your device maker with access to this information may assist the device maker to provide customer support or diagnose and address issues with the device. Providing data access to device makers also helps them understand how their devices are being used, which helps them make better devices in the future. We may charge device makers a fee to access this data.

Your device manufacturer may be able to identify you based on the serial number associated with the device.

Please note that any information you may have previously shared with a device maker may remain with the device maker if they have stored that information and cannot be removed or deleted by changing your sharing preference.

1.2.4 Options for Sharing Anonymized Information with Researchers or Other Research Databases

You may have the option to donate your anonymized data with different Researchers or Research organizations, or with Cancer device or pharmaceutical companies in need of longitudinal datasets. Cancer researchers have a very difficult time gaining access to quality Cancer data. We will give you the opportunity to make your anonymized information available to these organizations. By doing this we hope to contribute to a dramatic acceleration in the rate of innovation in Cancer care.

You will not be directly identifiable based on the information you choose to donate. However, it may be possible for others to identify you if you have made your information available publicly in other ways; for example, if you post pictures or information to social media that describes you or your health condition, such as tweeting a picture of your continuous glucose monitor readings, it may be possible for someone to correlate that with information in a Project Notebook dataset. For this reason, all donations of your information will require your explicit consent. Donated, anonymized information will be stored and made available without any of your personal Project Notebook account information. If you agree to donate your information, here is the information that will and will not be included (if provided):

We will not include in the anonymized datasets (1) freeform text and notes entered by you or your Care Team Members, or (2) any other data that could identify a specific individual.

The data from your device will be correlated across time and with the donated Data Owner information using a random, cryptographically secure user key (a “one-way hash”). Having this key allows researchers to correlate multiple data points over time from a single person, but does not allow them (or anyone else without internal access to Project Notebook servers) to identify the person.

You may be asked to donate your information via email or via using Project Notebook Apps. If you would like to change your donation preference, you may do so by using the appropriate interface in Project Notebook Apps. If you change your preference to stop donating your information, you will not be able to remove or delete anonymized information that was previously donated prior to the change.

1.2.5 Export, Delete, or Change Your Information

You can change the contact information you provided when you registered by going to Account Settings. You can change or delete other information and data you have provided by editing or deleting that information directly using the utilities and features available in the Project Notebook Apps. To learn how to export or delete your information, please visit support.Project Notebook.org.

1.2.6 Cancel Your Account

You can cancel your account at any time. Upon cancellation, we will cease all use of your data and delete your account information and data. Please visit support.Project Notebook.org to learn how to cancel your account.

1.2.7 Other Rights

You May Have Under HIPAA Project Notebook may enter into relationships with a number of institutions or health care providers, such as Clinicians, Researchers, or others, for whom Project Notebook will act as a “business associate” under the federal Privacy and Security Rules issued under the Health Information Portability and Accountability Act (“HIPAA”). If you are a patient of one of these institutions or other providers, or are participating in a research study conducted by one of these organizations, Project Notebook may have obligations to that institution or other provider under HIPAA and Project Notebook’s business associate contract with the institution or other provider that affect the information about you that the institution or provider stores in the Project Notebook platform. These “business associate” relationships will not affect information in your Project Notebook account.

1.2.8 Email Communications

You can choose to stop receiving marketing or informational emails from us by clicking the “unsubscribe” link at the bottom of any such email. We may from time to time send you certain communications such as regarding your account, the Project Notebook App or the Project Notebook Platform and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Use or this Privacy Policy).

1.3 How do I invite members to join my Care Team or invite others to use Project Notebook Apps?

If you would like to invite someone to become a member of your care team, we’ll ask you for the person’s email address for the sole purpose of sending an invitation. To do so, please select “Share” from within the Project Notebook for web application.

1.4 What about the practices of third-party applications that Data Owners can connect to Project Notebook Apps or the Project Notebook Platform?

Our Privacy Policy applies solely to information collected by and through the Project Notebook Apps. You may be able to connect this information to third-party applications from the Project Notebook Apps, or by connecting your Project Notebook account from within a third-party application, or you may choose to share your device data with a device maker. Please be aware that Project Notebook doesn’t control and isn’t responsible for the privacy and security practices of the third party services you choose to connect with or those of your device makers. However, all third-party developers that connect to the Project Notebook Platform will be required to certify that their privacy policy is consistent with the terms of this Privacy Policy. For example, third-party applications will need to agree to not disclose your personal information without your consent. We encourage you to become familiar with their information practices before choosing to share any personal information or data with them.

1.5 Who else has access to my information?

You can see who your information is shared with by logging into your Project Notebook account and selecting the “Share” link.

Some Clinicians or Researchers who you include on your Care Team may participate in other information sharing agreements, and may share some or all of your health information as part of those agreements. For example, your Clinician may participate in the T1D Exchange Registry, QI Collaborative, or other similar information sharing registry, which provides information collection and research services for a network of clinical sites. Please check with your health care provider, clinic, Clinician or Researcher to ask how they may be sharing your health information.

2. Information for Care Team Members

Data Owners have control of the information in their Project Notebook accounts. This means that as a Care Team Member your access to a Data Owner’s data and information is controlled by the Data Owner and that any comments or information that you add may be deleted by the Data Owner at any time.

Frequently Asked Questions for Care Team Members

2.1 What information does Project Notebook collect from Care Team Members and for what purposes?

2.1.1 Registration and Contact Information

To register as a Care Team Member, you must provide an email address and create a password. You use your email address and password to log in. We also collect contact information, such as your name, address, phone number, and certain non-personal information that does not itself directly identify you, such as your IP address. An IP address is a number assigned to you by your Internet service provider so you can access the Internet. Although we do receive IP addresses, we do not use them to identify you personally or disclose them to others.

We use this information to: deliver, administer and improve the Project Notebook Apps; provide customer service; improve and personalize your experience; better understand your needs and interests; fulfill requests you make; deliver special announcements and updates about the Project Notebook Apps; and contact you about any of the above as well as any changes to or notifications regarding your account.

2.1.2 Other Information You Provide to Us

We may also collect other information you provide to us through the Project Notebook Apps. As a Care Team Member, this information will mostly be information or comments about the Data Owner or Data Owners that add you as a Care Team Member using the Project Notebook Apps. We use the information you provide as a Care Team Member to display notes, comments and other features of the Project Notebook Apps. A Data Owner has the ability to delete information or comments you add to his or her account at any time.

A Data Owner has the option to donate anonymized information from his or her account to the Project Notebook Anonymized Cancer Database. If the Data Owner donates his or her information, information or data that you add to the Data Owner’s account that is being donated will exclude comments that you make on that account.

2.2 What choices do Care Team Members have?

A Data Owner owns all content you generate on that Data Owner’s accounts and you have no control over that information, except in the course of editing comments you have made as long as the Data Owner permits such changes. However, you can delete or change your personal information.

2.2.1 Change Your Information

You can change the contact information you provided when you registered by going to Account Settings.

2.2.2 Cancel Your Account

You can also cancel your account at any time. Upon cancellation, we will delete your account information but not information or comments you have added to any Data Owner accounts.

2.2.3 Email Communications

You can choose to stop receiving marketing or informational emails from us by clicking the “unsubscribe” link at the bottom of any such email. We may from time to time send you certain communications such as regarding your account, the Project Notebook App or the Project Notebook Platform and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Use or this Privacy Policy).

3. Information for Clinicians and Researchers

As a Clinician or Researcher, you will be able to create accounts and collect information on behalf of people that you provide care for, or people that are participating in a research study that you are conducting. These accounts are called Custodial Accounts. You can optionally provide an email address that will cause an account invitation to be sent to an individual, allowing that person to sign up for and claim the Project Notebook account, and become a Data Owner. When you create a Custodial Account, you have control over that account and information at the outset. Once the account is claimed by a Data Owner, that Data Owner takes over control and ownership of the information and account, and you become a member of that Data Owner’s Care Team.

Frequently Asked Questions for Clinicians and Researchers

3.1 What information does Project Notebook collect from Clinicians and Researchers and for what purposes?

3.1.1 Registration and Contact Information

To register for a Project Notebook account as a Clinician or Researcher, you must provide an email address and create a password. You use your email address and password to log in to the account. We also collect other contact information, such as your name, your clinic or institution name, address, phone number, and certain information that does not itself directly identify you, such as your IP address or your role within your organization. An IP address is a number assigned to you by your Internet service provider so you can access the Internet. Although we do receive IP addresses, we do not use them to identify you personally or disclose them to others.

We may use this information to: deliver, administer and improve the Project Notebook Apps; provide customer service; improve and personalize your experience; better understand your needs and interests; fulfill requests you make; deliver special announcements and updates about the Project Notebook Apps; and contact you about any of the above as well as any changes to or notifications regarding your account.

3.1.2 Other Information You Provide to Us; Custodial Accounts

We also collect other information you provide to us through the Project Notebook Apps. As a Clinician or Researcher, you will be able to create accounts for your patients or study subjects, called “Custodial Accounts.” When you create these accounts, you may choose to, but are not required to, identify those individuals by their name, date of birth, and an optional Medical Record Number (MRN). You may also optionally provide an email address for each individual. Providing an email address will initiate an email invitation that will allow the individual to sign up for Project Notebook and claim the account, thereby taking ownership of the account information. It is your responsibility to ensure the accuracy of that email address.

If an individual chooses to sign up for Project Notebook and claim an account, he or she then takes ownership of the account and becomes a Data Owner, as defined above. The account will be automatically shared with you, making you a Care Team Member, as defined above. The Data Owner may remove you as a Care Team Member at any time.

We may also collect other information you provide to us through the Project Notebook Apps. This may include gender, age and birth date, weight, height, treatment and diagnosis information, health and well-being related information (including diet and activity information), information identifying the Cancer monitoring and treatment devices you upload for individuals, and data that you upload from their Cancer monitoring and treatment devices using Project Notebook Uploader.

We use this information to provide the visualization, data analysis, and other features available through the Project Notebook Apps. When you seek support from us, the individual(s) providing you with support may need to access your information in order to identify the problem you are seeking support for, though the use of your information will only be used to help provide you with support.

3.1.3 Other Information that You Collect from Patients or Study Subjects

Through the course of providing care or conducting a research study, you may collect information other than through Project Notebook. Only information collected by Project Notebook or via Project Notebook Apps is covered by this Privacy Policy.

3.1.4 Business Associate Agreement

If Project Notebook will be acting as your business associate under the federal Privacy and Security Rules issued under the Health Information Portability and Accountability Act (“HIPAA”), our obligations regarding the privacy and security of the personal information you store in Project Notebook will be governed by a separate written business associate agreement between us. Project Notebook will not be subject to any business associate agreement unless it is executed on Project Notebook’s behalf by an authorized person.

3.2 What choices do Clinicians and Researchers have?

A Data Owner owns all content you generate on that Data Owner’s accounts and you have no control over that information, except in the course of editing comments you have made as long as the Data Owner permits such changes. However, you can delete or change your personal information.

3.2.1 Change Your Information

You can change the contact information you provided when you registered by going to Account Settings.

3.2.2 Cancel Your Account

You can also cancel your account at any time. Upon cancellation, we will delete your account information but not information or comments you have added to any Data Owner accounts.

3.2.3 Email Communications

You can choose to stop receiving marketing or informational emails from us by clicking the “unsubscribe” link at the bottom of any such email. We may from time to time send you certain communications such as regarding your account, the Project Notebook App or the Project Notebook Platform and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Use or this Privacy Policy).

4. Information for Everyone

The following information applies to all Users of the Project Notebook Apps and Project Notebook Platform: Data Owners, Care Team Members, Clinicians and Researchers.

Frequently Asked Questions for Everyone

4.1 Are there any territorial restrictions for using Project Notebook Apps?

At this time, Project Notebook Apps are only intended for use in the United States and the European Union (‘EU’). The Project Notebook Apps and Project Notebook Platform are hosted in the United States and all information is stored in the United States. By using the Project Notebook Apps and Project Notebook Platform you consent to processing and storage of your information in the United States. For further information if you are an EU resident and using the Project Notebook App or visiting the Project Notebook website from the EU, please see the section below on International Privacy Laws.

4.2 Do any third party service providers have access to my information?

We may employ independent companies or other third parties and individuals to help us provide, facilitate or improve the Project Notebook Apps (such as customer service support or data hosting). These service providers may have access to your personal information and data as necessary to perform their services for Project Notebook.

4.3 When can Project Notebook disclose my information?

Other than the sharing you have authorized, we will only disclose your personal information or data as disclosed in this Privacy Policy. We may disclose your information in the following circumstances:

Project Notebook may disclose anonymous or statistical information about the use of the Project Notebook Apps at any time without restriction.

4.4 How long does Project Notebook keep my information?

Project Notebook will retain your account and related information on your behalf as long as needed to support your use of the Project Notebook Apps, for necessary backup purposes and comply as necessary with our legal obligations, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. We may delete your account due to inactivity, but we will notify you by email prior to doing so and give you a reasonable opportunity to either transfer your information or begin active use of your account again.

4.5 How does Project Notebook secure my information?

To help protect the privacy of personal information and data you transmit using Project Notebook Apps, we use technology designed to encrypt your personal information and data before it is sent to us over the internet. In addition, we take reasonable physical, administrative, and technical steps to protect the personal information and data that you provide us against unauthorized access. However, the software, hardware and networks that support the Project Notebook Apps may, from time to time, require maintenance or experience problems or breaches of security beyond our control.

Please also be aware that despite our best intentions and the guidelines outlined in this Privacy Policy, no data transmission over the internet or encryption method can be guaranteed to be 100% secure. Project Notebook cannot guarantee the security of the information you provide us, and therefore you use Project Notebook Apps at your own risk.

While we take steps to protect your personal information and data and keep it secure, you also play a role in protecting your information. You can help to maintain the security of this information by using a unique, strong password, not sharing your account information and password with anyone, and by preventing unauthorized use of your computers and mobile devices.

4.6 What about information about children?

Project Notebook does not allow children under the age of 13 to register or use the Project Notebook Apps and we require that children between 13 and 18 must have their parent’s or legal guardian’s consent to register or use Project Notebook Apps. Project Notebook does not knowingly collect information from children under the age of 13. If we discover that a person under 13 has registered as a Data Owner or Care Team Member we will delete that person’s account.

4.7 What are my California Privacy Rights?

We act in accordance with the principle behind the California “Shine the Light” law, CA Civil Code § 1798.83, which gives consumers the right to know about certain personal information shared with third parties for their use in directly marketing their own products or services. We will never do that without your express permission, except as described in this Privacy Policy. Under California law, a California resident with whom we have an established relationship has the right to request certain information with respect to the types of personal information that Project Notebook has shared with third parties for their direct marketing purposes, and the identities of those third parties, during the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be in writing and sent to Project Notebook at the mailing address set forth below.

4.8 Does Project Notebook use cookies?

We use cookies (a piece of data or file that a website can send to your browser, which may then store it on your computer system) and similar technology to collect aggregate (non-personal) information about usage of Project Notebook Apps by all of our Users and to help us remember you and your preferences when you revisit the Project Notebook Apps. These cookies may stay on your browser into the future until they expire or you delete them. Some cookies that assist in the functionality of the Project Notebook Apps, like page loading, usually are erased when you close your browser window. You may prevent our use of cookies by changing the settings on your internet browser. If you block our cookies, the Project Notebook website and/or Project Notebook Apps may not function properly or provide full functionality. Further general information about cookies and how they work is available at www.allaboutcookies.org.

4.9 Does Project Notebook collect information automatically when I use the Project Notebook Apps?

We receive and store certain types of information whenever you interact with Project Notebook Apps. We automatically receive and record information on your activity on our server logs, including your IP address. Generally, we also automatically collect usage information, such as the features of the Project Notebook Apps that you use and how you use them, the number of Care Team Members, devices you upload, and how Data Owners and Care Team Members interact. We may use this information, as well as your personal information such as your email address, to provide personalized features and functionality, for example to provide reminders to upload data from your Cancer devices. We may also use this data to help us understand how you and other Users use parts of the Project Notebook Apps so that we can improve them. We may disclose anonymous statistical information to third parties about how Project Notebook Apps are used without your permission.

Project Notebook Apps may also produce error codes and other diagnostic logging information that help us improve our software. These logs include IP address, email address, local hostname, browser version, operating system version, connected devices, and software error stack trace. This information is only about Project Notebook Apps, and is only used by Project Notebook to improve Project Notebook Apps. These logs are only retained for 180 days.

4.10 Can third parties collect information about me when I use the Project Notebook Apps?

We do not allow third parties to place cookies through the Project Notebook Apps or to collect information about a consumer’s online activities over time and across different websites when he or she uses our Project Notebook Apps. We do not permit third parties to place cookies through our Project Notebook Apps to perform marketing functions but we may allow service providers to place cookies to assist us with analytic functions. For these analytic functions, we may use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our services, and to develop website content. This analytics data is not tied to any personal information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the services by going to http://tools.google.com/dlpage/gaoptout.

4.11 Does Project Notebook recognize Do Not Track signals?

We currently do not use technology that recognizes a “do-not-track” signal from your web browser.

4.12 International Privacy Laws

If you are using the Project Notebook Apps from outside the United States, please note that you are sending your information, including your personal information, to the United States, where Project Notebook’s servers are located. Your information may then be transferred within the United States or to another country. The United States or these other countries may not have data protection laws as comprehensive or protective as the laws of your country or of the European Union. However, Project Notebook’s collection, use, and processing of your information will in all events continue to be conducted in accordance with this Privacy Policy.

4.13 Additional Rights

Under the GDPR, residents of the European Union have specified rights in connection with their personal information held by Project Notebook. Project Notebook has chosen to provide these rights to all Project Notebook users. Therefore, in addition to the other rights described in this Privacy Policy, you have the right:

If you feel that Project Notebook is not abiding by the terms of this Privacy Policy, please contact Project Notebook Privacy Official at the contact information provided above.

If a Clinician or Researcher uses Project Notebook to store information about you and you do not own the account, and as you will not have control of the information associated with that account, you will need to contact the Clinician or Researcher, if you wish to access, correct, update or request removal of any of your information or if would like more information on the privacy practices concerning your personal information.

If any request remains unresolved, you also have the right to complain to your national data protection authority for your EU Member State where you are resident.

Project Notebook does not use your personal information for automated decision-making, as defined in the GDPR. Project Notebook will not make any decision solely by automated means without human involvement, including profiling, that will produce legal effects upon a user, or that will have a similarly significant effect upon a user. The Project Notebook apps may through automated means evaluate Cancer device and other data related to your health condition, and offer treatment recommendations to you and your treating physician. As is provided by the Terms of Use, Project Notebook’s recommendations are not substitutes for the evaluation of your health care needs by a qualified physician or for the diagnosis and treatment decisions for you that your physician will make. Project Notebook does not choose any treatment plan for you or decide the health care services users will receive. If the user authorizes it, all personal information the user has in Project Notebook will be available to the user’s physician, so that physician may use that information to make medical treatment decisions independently.

4.14 Legal Basis for Collection, Use, and Processing of Information

In accordance with the GDPR, the legal basis for our collection and processing of your information is your consent for us to do so. Your consent will be recorded when you register to use the Project Notebook Apps. You may withdraw your consent at any time by canceling your account, and the information in that account about you will be deleted. However, we may need to retain a portion of your information for a reasonable period of time for legitimate purposes that are reasonable necessary for the proper management and administration of Project Notebook’s business and the satisfaction of our legal obligations to third parties.