Abbott provides the AFibLife™ Application (“App”) to facilitate user education on atrial fibrillation and provides users the opportunity to use and share information relating to their experiences with atrial fibrillation.
Abbott’s privacy notice is part of our approach to transparency and protection of your personal information.
This privacy notice describes how Abbott collects, uses, and/or shares your personal information. Personal information is information that identifies you as an individual or could be used to reasonably identify you. Examples of Personal Information include, but are not limited to, your name, address and contact information.
A list of the Data Controllers for the processing of your personal data can be found in the +United Kingdom section of this document.
Abbott does not receive or process information you maintain in the App or share with the App from Apple Health Kit. For more information, see +About the App Functionality and Services and +Security of Personal Information below.
This summary is not comprehensive. You will need to read the relevant sections of the privacy notice below to fully understand how we process personal information.
The App uses your personal information to:
The App stores your Personal Information locally on your device (Abbott does not receive this Personal Information) as follows:
The App will access and temporarily display your Personal Information from Apple Health Kit; however this data is not stored in the App:
The App will collect information about the device, including a mobile device identifier and a unique app install string to help prevent users from downloading multiple versions of the app on one device.
Abbott will only process information where you turn on the App Usage Statistics or if you choose to provide us with information through customer support channels. Each of these uses are further explained below.
Customer support: If you choose to contact Abbott for technical or other customer support queries, Abbott may collect and process the below categories of Personal Information to provide you with that support:
App usage statistics: If you consent, Abbott will use analysis tools, including Microsoft App Center Analytics, for analytics purposes, and will collect country codes, information related to App performance including crash reports, and the viewing of materials within the App and the linked content (such as number of visits and time spent watching videos). Abbott only receives de-identified or anonymized analytics and does not have access to identifiable information about you. Abbott uses this information to assess and improve App performance, workflows, and content, to build models, algorithms, learnings, or intelligence, and develop, manufacture, have manufactured, license, market, and sell directly or indirectly, products and services. More information about Microsoft’s privacy practices can be found at https://privacy.microsoft.com. You have the right to withdraw your consent to share App usage statistics by navigating to the “Settings” section of the App and disabling the “App Usage Statistics” setting.
In-app purchases: You may choose to make in-app purchases for subscriptions and additional services. These in-app payments will be processed by Apple Pay and Google Pay, depending on the user’s device. Neither Abbott nor the App will have the technical ability to view, collect, or store any user payment or billing information. Abbott or its service providers may also collect information about a user’s device, including mobile device identifiers, device type, and device operating system, to ensure that users can access subscriptions and additional services that they have purchased. Abbott also receives aggregated and anonymized information on the number of in-app purchases made through Apple Pay and Google Pay associated revenue. This is not classed under applicable law as your Personal Information. More information about Apple Pay and Google Pay’s privacy practices can be found at https://www.apple.com/legal/applepayments/privacy-notice/ and https://support.google.com/googlepay/answer/9039712?hl=en.
Some of the Personal Information that you upload or store locally on your device within the App may be considered sensitive Personal Information under certain data protection laws, such as journal entries, medication logs, AFEQT Questionnaire responses and scores, CHA2DS2-VASc Calculator responses and scores, and health information accessed by the App from Apple Health Kit.
AFEQT responses and scores are stored on your device until you choose to delete them. They may also be shared with third parties of your choosing.
Information you import from Apple Health Kit are not stored in your device, but are queried and temporarily displayed within the App, and deleted when the App is closed.
Medication logs and CHA2DS2-VASc Calculator responses and scores are stored on your device until you choose to delete them.
Information you store in Apple Health Kit is not stored in the App, but is queried on demand and temporarily displayed within the App. See the Apple Health Kit Privacy Notice for more details.
Biometric data (facial or fingerprint data) utilized to access the App is not accessed or stored by the App and is not accessible to or collected by Abbott. This data is stored and processed exclusively by your mobile device and its operating system functionality, which notifies the App if the user requesting access has been successfully authenticated. See your mobile device Privacy Notice for more information.
Due to the nature of the App, it is possible to infer certain information relating to your health because you have downloaded the App. This information is not intentionally collected nor is it processed by Abbott or any of its affiliates or processors.
See +Collection and Processing of Your Personal Information below.
For more information, including information about Abbott’s use of your data, see +Abbott’s Own Use of Your Personal Information and +Retention of Personal Information below.
We strictly limit who we share Personal Information with and do not sell your Personal Information to third-parties for commercial benefit, nor will we share your Personal Information with third-parties for cross-context behavioural advertising or targeted advertising. We may share Personal Information with our affiliated companies to help support and provide technical assistance for the App, for compliance purposes, or to perform troubleshooting/ diagnostics and broader analysis to detect systemic issues. For more information, see +Disclosure of Personal Information by Us below.
Where your location grants you certain rights in relation to your Personal Information, we will respond to such requests. For more information, see +How You Can Access and Correct Personal Information and Your Rights below.
If you contact us for customer support in relation to the App or consent to us collecting App usage statistics, such information is stored on servers in the United States of America. For more information, see +Data Storage.
If you have questions, comments, or complaints about Abbott’s privacy practices, please contact us by clicking on the “Contact Us” link in one of our websites or emailing us at privacy@abbott.com. For more information, see +Contact Us below.
If we update this Privacy Notice with changes, we will alert you via the App. For more information, see +Changes to this Privacy Notice below.
Abbott provides the AFibLife™ Application (“App”) (the “Services”). Throughout this Privacy Notice, references to “Abbott,” “we,” “us,” and “our,” mean Abbott Laboratories, 100 Abbott Park Road, Abbott Park, IL 60064, United States.
We recognize the importance of data protection and privacy and are committed to protecting Personal Information, including health-related information.
Please read this Privacy Notice carefully before using the AFibLife™ App as it applies to the storage of Personal Information, including health-related data, within the App on your device, and to Personal Information processed by Abbott, certain affiliated companies, and processors, if any, as described below.
By clicking “I Accept”, you acknowledge that you have read this Privacy Notice, and you affirm that you are 18 years of age or older.
The App is not directed to individuals under the age of 18, and Abbott does not knowingly collect or maintain Personal Information online from individuals we actually know at the time of collection are under the age of 18. Should we discover that we have collected Personal Information online from an individual who is under 18, we will take reasonable steps to promptly delete that Personal Information. If you have concerns over the collection of children’s Personal Information on the App, please contact us at the information provided in the +Contact Us section below.
If you do not agree with this Privacy Notice, please do not use the AFibLife™ App or provide us with any Personal Information.
By accepting or agreeing to this Privacy Notice, you explicitly acknowledge that your use of this App is subject to this Privacy Notice and to the processing and/or transfer of Personal Information, as described in this Privacy Notice.
You acknowledge that you are not under any legal obligation to provide Personal Information to Abbott.
Abbott Laboratories is the manufacturer of AFibLife™ App. See the list and contact point of Abbott affiliates at the end of the document.
Abbott provides the AfibLife™ Application (“App”) to facilitate user education on atrial fibrillation and provides users the opportunity to use and share information relating to their experiences with atrial fibrillation.
“Personal Information” is information that identifies or relates to you as an individual or could be used to reasonably identify you. Personal Information includes “personal data” as that term is defined in applicable privacy laws and regulations. Personal Information also includes “Sensitive Personal Information,” as defined in +Sensitive Personal Information, except where otherwise noted. Personal Information does not include information that is publicly available, de-identified or anonymized, or aggregated.
The App uses your personal information to:
The App will store locally on your device the following Personal Information that you upload (Abbott does not receive this Personal Information):
The App will access and temporarily display your Personal Information from Apple Health Kit; however this data is not stored in the App:
The above information is stored locally on your device and is not accessed, stored or otherwise processed by Abbott.
Abbott will only process information where you turn on the App Usage Statistics or if you choose to provide us with information through customer support channels. Each of these uses are further explained below.
Customer support: If you choose to contact Abbott for technical or other customer support queries, Abbott may collect and process the below categories of Personal Information to provide you with that support:
The App will collect information about the device, including a mobile device identifier and a unique app install string to help prevent users from downloading multiple versions of the app on one device.
App usage statistics: If you consent, Abbott will use analysis tools, including Microsoft App Center Analytics, for analytics purposes, and will collect country codes, information related to App performance including crash reports, and the viewing of materials within the App and the linked content (such as number of visits and time spent watching videos). Abbott only receives de-identified or anonymized analytics, and does not have access to identifiable information about you. Abbott uses this information to assess and improve App performance, workflows, and content, to build models, algorithms, learnings, or intelligence, and develop, manufacture, have manufactured, license, market, and sell directly or indirectly, products and services. More information about Microsoft’s privacy practices can be found at https://privacy.microsoft.com. You have the right to withdraw your consent to share App usage statistics by navigating to the “Settings” section of the App and disabling the “App Usage Statistics” setting.
In-app purchases: You may choose to make in-app purchases for subscriptions and additional services. These in-app payments will be processed by Apple Pay and Google Pay, depending on the user’s device. Neither Abbott nor the App will have the technical ability to view, collect, or store any user payment or billing information. Abbott or its service providers may also collect information about a user’s device, including mobile device identifiers, device type, and device operating system, to ensure that users can access subscriptions and additional services that they have purchased. Abbott also receives aggregated and anonymized information on the number of in-app purchases made through Apple Pay and Google Pay associated revenue. More information about Apple Pay and Google Pay’s privacy practices can be found at https://www.apple.com/legal/applepayments/privacy-notice/ and https://support.google.com/googlepay/answer/9039712?hl=en.
Some of the Personal Information that you upload or store locally on your device within the App may be considered Sensitive Personal Information under certain data protection laws, such as journal entries, medication logs, AFEQT Questionnaire responses and scores, CHA2DS2-VASc Calculator responses and scores, and health information accessed by the App from Apple Health Kit.
AFEQT responses and scores are stored on your device until you choose to delete them. They may also be shared with third parties of your choosing.
Information you import from Apple Health Kit are not stored in your device, but are queried and temporarily displayed within the App, and deleted when the App is closed.
Medication logs and CHA2DS2-VASc Calculator responses and scores are stored on your device until you choose to delete them.
Information you store in Apple Health Kit is not stored in the App, but is queried on demand and temporarily displayed within the App.
Due to the nature of the App, it is possible to infer certain information relating to your health merely because you have downloaded the App. Any health-related information associated with the App is not collected or processed by Abbott or any of its affiliates or processors.
Biometric data (facial or fingerprint data) utilized to access the App is never accessed or stored by the App and is not accessible to or collected by Abbott. This data is stored and processed exclusively by your mobile device and its operating system functionality.
As mentioned above, all Personal Information collected by the App is stored on your device, unless you choose to contact Abbott for customer support purposes, and/or consent to App usage statistics.
Information you provide while requesting technical or customer support and App usage statistics collected by Abbott for the purpose of analytics is stored in a secure environment managed by Abbott, which is located in the United States. We have implemented appropriate security measures and controls to protect Personal Information.
Personal Information about your in-App purchases is stored by Abbott’s processors in the United States. Abbott ensures its processors implement appropriate security measures and controls to protect your Personal Information.
By downloading, installing, accessing, and using the App or clicking “I Accept,” you consent to the transfer of personal data that you provide when requesting customer support to Abbott in the United States, a country providing a level of data protection that may be lower than the level of data protection in your jurisdiction. You accept that your personal data may not be protected in the same way in the United States as they are in your jurisdiction.
See also +Security of Personal Information.
Unless you choose to contact Abbott for customer support purposes, and/or consent to Abbott conducting App usage statistics, Abbott does not collect or store any Personal Information processed by the App. AFEQT Questionnaire responses and scores, CHA2DS2-VASc Calculator responses and scores and medication logs are stored on your device until you delete them. Information you provide in Apple Health Kit is not stored in the App, but is queried on demand and temporarily displayed within the App.
Abbott will keep any Personal Information collected by Abbott for the purpose of providing technical or customer support for 30 days following receipt or until the issue is resolved, whichever is sooner.
Abbott will keep Personal Information collected for App usage analytics purposes for 28 days from collection.
Personal Information about your in-app purchases will be kept by the purchase processors for 5 years.
We may also keep your Personal Information for as long as necessary for the purposes described in this Privacy Notice or otherwise authorized by law. This includes providing you with the service you have requested from us or to comply with applicable legal requirements. It also includes keeping your Personal Information for so long as there is any possibility that you or we may wish to bring a legal claim, or where we are required to keep your Personal Information for legal or regulatory reasons. If you wish to receive further information regarding our record retention procedures, please contact us using the contact details provided under the +Contact Us section below.
The section +Deleting Your Information from the App explains how you can arrange to have your information deleted from the App.
To the extent Abbott processes your Personal Information, Abbott may share such Personal Information as follows:
As part of the functionality of the App, you have the ability to send, via the default email application on your device, your AFEQT Questionnaire responses and scores. For the avoidance of doubt, you are completely in control of whether and with whom to share this Personal Information and Abbott has no control and is not a controller of your Personal Information when you use this functionality.
Abbott has implemented appropriate security controls to protect Personal Information that it collects and processes from accidental or unlawful destruction or accidental loss, alteration, disclosure, or access.
Please be aware that the App’s services may be unavailable during periods of routine maintenance.
Depending on your place of residence, you may have the right to: (a) access the Personal Information we hold about you; (b) request we correct any inaccurate Personal Information we hold about you; (c) delete any Personal Information we hold about you; (d) restrict the processing of Personal Information we hold about you; (e) object to the processing of Personal Information we hold about you; and/or (f) receive any Personal Information you have provided to us on the basis of your consent in a structured and commonly used machine-readable format or have such Personal Information transmitted to another company. Please note that Abbott does not have access to the data in the App, and therefore cannot correct, delete or transmit the data housed in the APP. Please further note that Abbott does not carry out any automated decision making.
When the processing of your data is based on consent, you can withdraw consent at any time. It will not affect the lawfulness of processing of your Personal Information that was collected and is processed prior to your withdrawing consent.
To request the exercise of these rights, you may contact us using any of the methods set out in the section entitled +Contact Us. See +California and other U.S. States with Consumer Data Protection Laws and +United Kingdom for more information about your rights..
You can delete your AFEQT(s) responses and scores, CHA2DS2-VASc Calculator responses and scores, medication logs and other information stored in the App from within the App. Deleting the App will delete all of your Personal Information stored in the App. For additional support, you can contact us at AFibLife@Abbott.com. Any Personal Information that you have previously downloaded to your device or have sent to your clinician (or anyone else) will not be deleted by deleting the App. Please be aware that if you delete your Personal Information in the App, Abbott will still retain aggregated and anonymized information it has already received and may need to retain certain Personal Information it has collected as part of providing customer support, as required by law.
If you have questions, concerns or complaints about your Personal Information in the App or wish to exercise your data protection rights, please contact us by clicking on the “Contact Us” link in one of our websites or emailing us at privacy@abbott.com. Alternatively, you may write to us at:
Attn: Abbott Medical Device Privacy Officer, 100 Abbott Park Road, Dept. O36X. Bldg. APo6A, Abbott Park, IL 60064
If you are a UK based user, you can also contact Abbott data protection officer at eu-dpo@abbott.com. Information related to the Data Controllers for your personal information can be found below in the +United Kingdom section.
In all communications to us, please include a detailed explanation of your request.
You have the right to lodge a complaint with your local data protection authority if you feel your privacy rights have been infringed.
This Privacy Notice is kept under regular review. If we make changes to our privacy practices, an updated version of this Privacy Notice will reflect those changes. You will be alerted to updates to this Privacy Notice via the App.
Without prejudice to your rights under applicable law, we reserve the right to update and amend this Privacy Notice without prior notice to reflect technological advancements, legal and regulatory changes and good business practices to the extent that it does not change the privacy practices as set out in this Privacy Notice.
Customer Requests
Depending on where you reside, you may have certain rights and choices (with certain limitations and exceptions) regarding our processing of your Personal Information. Please note that some of these rights may vary depending on your state of residence.
Additionally, residents of California, Colorado, Virginia, Utah and Connecticut have certain rights with respect to the collection and use of their Personal Information. Those rights may vary by state. Such rights may be effectuated by submitting a request by clicking Privacy Rights Request. The potential rights include the right to:
Once you have submitted your request, we will respond within the time frame permitted by the applicable U.S. state law. To help protect the security of your Personal Information, Abbott will need to verify your identity in connection with any requests. We may contact you by email to verify your request. Depending on your request, we may ask you for information such as your name, an email address, or phone number that you have used with Abbott. We take steps to ensure that only you or your authorized representative can exercise rights with respect to your Personal Information. If you are an authorized agent making a request, we may require and request additional information to protect the Personal Information entrusted to Abbott, including information to verify that you are authorized to make that request.
There may be situations where we cannot grant your request, for example if you make a request for access and we cannot verify your identity, we will not be able to comply with the request. We may also be unable to comply with your request to delete if we have a legal or regulatory obligation to keep your Personal Information, such as when you participate in scientific research. Other reasons your request may be denied are if it jeopardizes the privacy of others or would be impracticable to honor.
Where we deny your request in whole or in part, we will take steps to inform you of the denial and provide an explanation of our actions and the reasons for the denial. If you are a Colorado, Connecticut or Virginia resident, you have the right to appeal Abbott’s decision to deny your request regarding your Personal Information, in whole or in part. To appeal our decision click Notice of Appeal. We will process and respond to your appeal within the time frame permitted by the applicable U.S. state law.
We will not discriminate against you if you exercise your rights as described in this Privacy Notice. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality of products or Services. We will not restrict or deny you access to our services or provide a different level of quality of products or services because of choices and requests you make in connection with your Personal Information. Please note, certain choices may affect our ability to deliver the Services.
You may exercise any of your applicable rights and choices set forth above in relation to your Personal Information by contacting us using the details provided under +Contact Us, by clicking Privacy Rights Request, or by visiting www.Abbott.com and clicking the “Your Privacy Choices” link found at the bottom of the website.
Categories of Personal Information That May Be Collected and Disclosed
| Categories of Personal Information We May Collect, Disclose, or Share | Purposes for Collection / Use | Applicable California Residents | Categories of Third Parties To Whom PI may be Disclosed or Shared |
|---|---|---|---|
| If you choose to contact us for support: Name, contact details (e.g., name, email address) | Provide you with technical or customer support relating to the App | App users | Abbott family of companies, service providers, government/law enforcement where necessary |
| Sensitive Personal Information, including health-related information (e.g., heart and activity-related information imported from Apple Health Kit, AFEQT questionnaire responses and scores, CHA2DS2-VASc Calculator responses and scores, journal entries, medication logs) | Provide you with our Services | App users | Not applicable; this information is stored locally on the user’s device and cannot be viewed or otherwise accessed by Abbott |
| Financial and payment information (e.g., information used to complete a transaction) | Provide you with our services | App users | Apple, Google |
| Device details (e.g., mobile device identifier, device type, device operator system) | Provide you with our services | App users | Service providers |
| In-app activity usage (e.g., device identifiers and information about the features of the app you use) | Track aggregated usage statistics, fix bugs | App users | Abbott family of companies, service providers |
a. Personal Information the App collects, how it’s used and shared, and the lawful basis for processing
| Categories of Personal Information the App Collects, Discloses, or Shares | Purposes for Collection / Use | Lawful Basis | Controller | Categories of Third Parties To Whom PI may be Disclosed or Shared |
|---|---|---|---|---|
| If you choose to contact us for support: Name, contact details (e.g., name, email address) | To provide you with technical or customer support relating to the App | Performance of a contract under Art. 6 (1) (b) UK GDPR | Abbott | Abbott family of companies, service providers, government/law enforcement where necessary |
| Sensitive Personal Information, including health-related information (e.g., heart and activity-related information imported from Apple Health Kit, AFEQT questionnaire responses and scores, CHA2DS2-VASc Calculator responses and scores, journal entries, medication logs) | Provide you with our Services | Performance of a contract with you under Art. 6 (1) (b) UK GDPR | App user | Not applicable; this information is stored locally on the user’s device and cannot be viewed or otherwise accessed by Abbott |
| Financial and payment information (e.g., information used to complete a transaction) | Provide you with our services | Performance of a contract with you under Art. 6 (1) (b) UK GDPR | Apple, Google | Service Providers |
| Device details (e.g., mobile device identifier, device type, device operator system) | Provide you with our services | Performance of a contract with you under Art. 6 (1) (b) UK GDPR | RevenueCat, Inc 1032 E Brandon Blvd #3003 Brandon, FL 33511 United States Compliance@revenuecat.com | Service providers |
| In-app activity usage (e.g., device identifiers and information about the features of the app you use) | Track aggregated usage statistics, fix bugs | Your consent under to Art. 6 (1) (a) UK GDPR | Apple, Google, Microsoft | Abbott family of companies, service providers |
b. International Data Transfers:
Your Personal Information is stored on your mobile device. Abbott or our service providers may access your data for the purpose of analytics as set out in +Purposes for Abbott’s Collection and Processing of Your Personal Information. For this Abbott relies on EU Standard Contractual Clauses. For a copy of the EU Standard Contractual Clauses, you may contact us at privacy@abbott.com.
c. Data Protection Officer: The contact details of our data protection officer can be found here: https://www.abbott.com/eu-dpo.html
d. Contact Us: In addition to the contact means provided in section 1 above, you may also contact us via the following EU contact means:
In all communications to us, please include the email address used relating to the App, and a detailed explanation of your request.
e. Your rights:
Under the conditions set out under applicable law (i.e., the UK GDPR), you have the following rights:
Please note that if you withdraw your consent relating to the provision of the App services and related maintenance, support and troubleshooting activities, we will be unable to further provide App services and the App to you and consequently you will not be able to further use the App services and the App upon the withdrawal.
Please note that the aforementioned rights might be limited under the applicable national data protection law.
You can exercise your rights by using any of the methods described in the section + Contact Us.
For more information on your rights, please see:
In case of complaints, you also have the right to lodge a complaint with the Information Commissioner’s Office in the United Kingdom.
You may find the contact details of the UK Information Commissioner’s Office under the following link: https://ico.org.uk/global/contact-us/.
f. UK Representative:
Abbott has appointed the following local representative in the UK:
Abbott Medical U.K. Limited
Elder House
Blythe Valley Business Park
Central Boulevard, Solihull
B90 8AJ, United Kingdom
