ACT on Vaping Mobile Application Privacy Policy, v1, September 22, 2023
1. BACKGROUND
ACT on Vaping is an cell phone-based application for vaping cessation created at Fred Hutchinson Cancer Center (Fred Hutch) in Seattle, Washington. Fred Hutch respects your privacy and is committed to protecting it through compliance with this Privacy Policy (“Policy”). This Policy applies to information we collect through our ACT on Vaping app and website. This Policy does not apply to information that we collect offline or in any other apps or websites. This Policy explains how we collect, use, disclose, and safeguard the information you provide to us so that you can make an informed decision when using ACT on Vaping app. If you have questions, please contact us at ACTonVaping@fredhutch.org. By using ACT on Vaping or otherwise providing your information to us, you agree to the terms of this Policy. If you do not agree with the terms of this Policy, please stop using ACT on Vaping.
2. INFORMATION WE COLLECT
We collect some non-personal information and some personally identifiable information (PII) when you access ACT on Vaping through the mobile application. Non-personal information includes information that cannot be used to identify you, individually, like anonymous user stories and usage data, number of clicks that you make as you navigate the mobile application, etc. Personal Information includes information that can be used to identify you such as your email address and location data, should you choose to provide this information. We may, directly or indirectly through the services of others, including by automated means and by means of providing maintenance and support services, collect and store information regarding your use of the ACT on Vaping app, such as type of device through which the app is accessed and used, dates and times of use, activities conducted using the app, the operating system/platform you are using, and your IP address. The collection of this information is regulated by the Fred Hutchinson Cancer Center's Human Subjects Institutional Review Board.
3. HOW WE USE PERSONAL INFORMATION
When using ACT on Vaping, we may ask you to provide us with some personally identifiable information to create your User profile and to support your use of ACT on Vaping. ACT on Vaping includes an engaging and personalized experience for vaping cessation program participants (Users). To effectively deliver our ACT on Vaping to our users we may collect, store, and use personally identifiable information that you provided to us when you registered for ACT on Vaping. The use of this information is regulated by the Fred Hutchinson Cancer Center's Human Subjects Institutional Review Board. We may use personally identifiable information you provided to us to respond to you, to provide what you requested, or to update you about changes to our Privacy Policy. We use identified information (information that is linked to your study identification number) to measure ACT on Vaping’s impact and effectiveness to Users, and to conduct surveys and continue our research at Fred Hutchinson Cancer Center, which may result in published reports or articles. De-identified information is used in our reports, research, surveys and results. In order to protect your privacy, we do not include any personally identifiable information in our research reports. You agree that we may use information that we collect about you or that you provide to us in order to provide you with the app and its contents, including but not limited to improving the performance of the app, developing updates, verifying compliance with our terms of use; enforcing our rights, including all intellectual property rights in and to the app, and recognize you when you return to our app.
4. DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information that does not identify you without restriction. In addition, we may disclose your personal information or other information about you as follows:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce our rights arising from any contracts entered into between you and us.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of any individual or entity.
- To fulfill the purpose for which you provide it.
- For any other purpose with your consent.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
5. HOW WE PROTECT YOUR PERSONALLY IDENTIFIABLE INFORMATION
Only ACT on Vaping study team members with the need to access your information are granted access to your PII. We store PII and other data for as long as it is allowed by Fred Hutchinson Cancer Center's Human Subjects Institutional Review Board. We have implemented measures designed to secure your PII from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. You are responsible for keeping your password for the app confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your PII, we cannot guarantee the security of your PII transmitted through our app. Any transmission of PII is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
6. UPDATES TO PRIVACY POLICY
We may update our Privacy Policy from time to time. If we make material changes to how we treat our Users' PII, we will notify you through our app and include the opportunity to stop using ACT on Vaping. Your continued use of the ACT on Vaping app after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.