PKG System Privacy Notice
Use of the PKG® System
Global Kinetics Pty Ltd (GK) is the provider and manufacturer of a system incorporating: the medical device known as the PKG® Watch; the internet portal or tablet computer used to upload data, and download and display results; and the PKG® (PKG® System).
The PKG® Watch records your movement for seven days as you go about your daily activities, and vibrates to remind you to take your medication as prescribed by your healthcare professional. At the end of the recording, the movement recording is uploaded from your PKG® Watch by either GK, or your clinic.
After the data is uploaded, it is analysed and provided to your healthcare professional (via the internet portal or a tablet computer) in a detailed document known as a PKG®. The PKG® is a graphical representation of your symptoms and can help your healthcare professional assess the state of your Parkinson’s symptoms at the time of recording, and assist them in making decisions about your treatment.
Collection of Personal Information through the PKG® System
“Personal Information” means any information relating to an identified or identifiable natural person. Such a person is one who can be identified 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 person.
GK collects Personal Information about you related to your use of the PKG® System which is reasonably necessary for, or directly related to, its functions and activities as a provider of medical devices and related services.
Types of Personal Information that GK collects
The Personal Information GK collects related to your use of the PKG® System may include:
- your full name;
- your address;
- your date of birth;
- your telephone number;
- name of treating physician and treating clinic;
- details of your Parkinson’s disease medication: times, dosages, medication types;
- a patient code, or other patient assignation, assigned by your treating clinic;
- whether you are treated with advanced Parkinson’s disease therapies; and
- your side of the body most affected by Parkinson’s disease.
Some of this Personal Information is collected via your healthcare professional or from you, directly, in your communications with GK by telephone, mail and email. Some data is collected directly from the PKG® Watch itself after it has been worn by you. Some of this information is generated in the analysis process. This includes the movement recording data which comprises raw accelerometry data, bradykinesia, dyskinesia and fluctuation scores, immobility, tremor, off-wrist time and self-reported medication consumption times.
Use and Disclosure
GK will use your Personal Information for the primary purpose for which it is collected, which generally includes the following purposes:
- in the course of the provision of the PKG® Watch that has been requested by your healthcare professional, and the related services;
- in the course of supporting you and your healthcare professional in your use of the PKG® Watch and your ongoing care;
- in providing your healthcare professional with the PKG® and, in some cases, a written summary of key measures on your PKG®. (Your Personal Information may be shared with third parties who are contracted to assist GK in preparing or summarising the PKG®. These third parties are obliged by GK to protect your Personal Information);
- administering clinical trials or other similar programs in which you agree to be involved; and
- compliance with regulatory requirements, such as maintaining a record of medical queries, complaints, adverse events and recalls relating to the PKG® Watch.
GK may also use your Personal Information to:
- provide you with updated product or safety information with respect to the PKG® Watch;
- maintain business records; and
- in addition, use for purposes permitted or required by law, and purposes for which you have provided your consent, via a GK consent form.
GK will only use or disclose your Personal Information for a purpose that was not the primary purpose for which GK collected it if you would reasonably expect us to do so or if GK has your consent. GK may also use or disclose Personal Information if GK is required or authorised by law to do so.
Cross Border Data Transfer
The Personal Information collected by GK through your use of the PKG® Watch is stored safely in the region in which it was collected. GK will only transfer Personal Information outside that region with your consent, or otherwise in compliance with the relevant local privacy and data protection laws.
Access, Correction, Revocation and Complaints
You have the right, in most cases, to access your Personal Information that GK holds at any time. GK takes reasonable steps to ensure that any Personal Information it holds about you is up-to-date, accurate and complete. You may have the right to oppose or limit the collection and processing of your information as described in this privacy notice, or to revoke your consent, although GK may be unable to provide services related to the PKG® System to you if you oppose this processing or if you revoke consent.
If you would like to access, review, correct, delete, or inquire about your information, place limitations on the collection or processing of your information, or revoke your consent, please send us a request at the address or e-mail provided below.
Please note that GK may need to take additional steps, such as to verify your identity, before GK can grant your request. As permitted by law, GK will notify you of the basis for any denial of your request.
You may contact GK’s Data Privacy Officer at firstname.lastname@example.org or at:
Global Kinetics Pty Ltd Attention: Data Privacy Officer Level 9, 31 Queen Street Melbourne, Victoria 3000, Australia