POLICY SUMMARY

What's MIRspiro

The MIRspiro is a Software developed that allow you to bring, in association with specific dispositive, spirometric and oxyometric tests. The User would perform this tests by blowing into a dispositive. The Software will receive anonymous raw data from the dispositive and display relevant diagnostic results to the User. The Device and the Software shall be paired by the User by a Bluetooth Low Energy connection.

There are two different data process scopes, explained separately below

A) Data processed for Software improvement

For data processing purposes described below, MIR is Data Controller pursuant art. 4 of the General Data Protection Regulation (GDPR).

Data subject is healthcare professional.

For the sole purpose of enabling MIR to improve the Software, including its usability, the user (the healthcare professional) transmits information relating to:
- MIR Dispositive associated at the Software
- Email address associated with the registration (device registration is required for product activation)
- Information about software errors (errors can also be transmitted by the specific platforms from which the user has obtained the software)
The user has to give the consent to the processing of his personal data for this purpose.
MIR doesn’t process personal data patients collected by the Software.

The Data is processed in a proper manner and the Software shall take appropriate security measures to prevent involuntary modification or destruction of the Data during the transfer from user installed software (encrypted transmission).

The Data is processed exclusively in the IT systems and applications managed by MIR.
Errors can also be transmitted by the specific platforms from which the user has obtained the software

The Data is kept for one year, then they are subjected to anonymization for statistical purposes.

If you need to contact MIR to access or modify your Personal Data or for any questions relating to this Privacy Statement, please contact gdpr@spirometry.com

MIR doesn't share or transfer this Data.

B) Data processed for healthcare purposes

This Software is made for healthcare professionals.
So, the healthcare professional that uses the Software, pursuant art. 4 of the General Data Protection Regulation (GDPR), is Data Controller.
Pursuant art. 13 GDPR, the Data Controller provides patients with all information on how personal data is processed within their organization, including this Software use.
If this product is used for personal use it is not necessary to identify the Data Controller.

For personal data processed for healthcare purposes data subject are patients.

The Software requires the following data:
1. anthropometric data such as weight, height, gender (input by the user);
2. personal data such as name, age and ethnic group (input by the user);
3. expiratory spirometry parameters (received by the meter)
Data Controller process these data for healthcare purposes.

According to the official Guidelines in Spirometry released by the World's most recognized Respiratory Associations such as the American Thoracic Society and the European Thoracic Society, above mentioned personal and anthropometric data are mandatory to calculate accurate and reliable spirometry test results. Consequently, all data collected by the Software are necessary for the Software to perform its functionalities.

• Calculate of spirometry parameters target value to be compared with the measured values
• Provide the spirometry test result based on the comparison between measure values and target values

The Software allows you to extract the data entered in different formats. This operation is carried out exclusively by the healthcare professional.

You have the right to request Data Controller to confirm whether your Personal Data is processed or not, and to request access and rectification or deletion of the same or limitation of the processing that concerns you or to object to the processing of the themselves, as well as the right to data portability. With reference to the right to data portability, you have the right to receive your Personal Data in a structured format, commonly used and readable by an automatic device and, under certain circumstances, to request the communication of such data to another holder of the treatment without impediment by the data controller to whom you have provided them.

Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

The individual owner of the device where this Software is installed.

The person to whom the Personal Data refers.

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
The Data Controller, unless otherwise specified, is the User.

It's the MIR application related to a specific medical dispositive.

We may update our Privacy Policy from time to time. You are advised to review this Privacy Policy periodically for any changes here https://mymir.spirometry.com/mirspiro-privacy-policy.
Changes to this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, please contact us gdpr@spirometry.com