This Privacy
Policy applies to your use of the huruapp.org website and its android
application (the “App”) and contains policies
regarding the collection, use and disclosure of your data and
content when you use the App.
The development
and pilot testing of Huru website and App is part of a UNODC project with
implementing partner Associazione Casa Famiglia Rosetta
(ACFR) on improving the capacity of the
system of drug use disorders treatment services to provide ethical,
evidence-based and humane treatment to persons with drug use disorders in
Tanga, Tanzania under the global programme GLOJ71: TreatNet – Treating drug use
disorders and its health consequences.
As part of the
above-mentioned project ACFR has partnered with a team of the Muhimbili
University of Health and Allied Sciences School of Public
Health (MUHAS) and the Tanzanian Ministry of Health, Community
Development, Gender, Elderly and Children (MoHCDEC).
In general, all
rights in this project belong to UNODC. However, when it comes, specifically
regarding the Huru App and website, the UNODC is referring to Article VIII on
Intellectual Property Rights in the project cooperation agreement between the
UNODC and the ACFR, dated on July 26, 2019. Therefore, UNODC agrees that while
for the pilot testing ACFR and MUHAS will hold the intellectual property rights of the Huru App and website, ultimately, the MoHCDEC Tanzania is the owner and will grant UNODC the permanent,
royalty free, non- exclusive and non-transferable license.
The Huru App is a mobile and
web-based application for two target population, people with substance use disorders and service providers working for people with substance
use disorders.
As the development of the Huru website and App has just started,
this privacy policy
document will refer to the different stages of implementation. The Huru
website and App will have the exact same components and only differ in the mode
of use. While to access the website users will
need a PC or laptop,
accessing the App is more practical, as any smartphone with Android function
will be sufficient. The development of the Huru website will be launched prior
to the Huru App to allow any technical improvements before the official launch.
The Huru App and website will have two components. One will focus on
information sharing (official IEC materials,
science-based articles on treatment of substance use disorders, available
services for people with
substance use disorders, video testimonials of people affected by SUD who
successfully participated in treatment) and the other part will be on
information collecting.
For the
collection of information and data, the MUHAS has successfully obtained Ethical
Clearance, dated on December 7, 2020 which will expire on December 6, 2021.
Ethical Clearance was obtained to assess the knowledge, attitude, substance use
practices and the potential of deploying mHealth intervention among people with
drug use disorders in Tanga Municipality and Muheza District. These two
locations will also be the only locations focuse on in this App and website, at
least for the piloting phase.
Thus, the
privacy policy will change as the App and website develops and any changes will
not affect data that was collected under a previous version. All parties
involved in this project will ensure the protection of data for the target
population who are people with substance use disorders.
However, the ultimate aim is to expand to the whole country and include all available services for people with substance use
disorders in Tanzania. Therefore, the App and website will be owned by the
MoHCDEC to ensure sustainability.
While the App
and website provides a unique opportunity of a platform for a vulnerable
population like people who are affected by substance use disorders to be heard,
there will be no additional services
provided other than information sharing.
For the time being this platform
does not have any capacity of providing actual services (e.g. counselling) to
the users but will provide information on available services
in Tanga Municipality and Muheza District.
Referral will not be explicitly offered to the user, as the user has to
individually decide whether they want to receive
any treatment. If any modifications substantially change regarding your rights, the
developers will provide notice on the App and the website.
This app
targets two types of users’ interfaces: i) people with substance use disorders
(SUDs) and ii) healthcare workers.
i)
For the user interface for
the people with SUDs: no registration is required, as the App and website serves as an
information site and the visit is entirely anonymous. Both interfaces do not collect
data regarding IP addresses. For this type of user, the app and website are
used to access Information, Education and Communication (IEC) materials on
promoting evidence-based drug treatment and care and also enabling
them to know where to access services
in Tanga Municipality and Muheza District. There
will be a table with available evidence-based
treatment services visible that offer access
to pharmacological and psychosocial treatment
for people with substance use disorders. The IEC materials will be
promoting positive behaviour among people with SUDs to improve their quality of life.
ii)
For the user interface for the healthcare workers: there is a special
interface for this user group which requires registration using any name as user name and phone
number for authentication purposes and validation of user actions. The reason
of having a separate interface for healthcare workers is to allow them
expanding their knowledge in
providing evidence-based drug treatment and other related services to people
with SUD. This part is related to another component
of the project, which
belongs to the capacity building part. Part of the information shared for
health workers will be the summary points of the Universal Treatment Curriculum (UTC) Basic Modules and Elements of the
Rural Treatment Curriculum used in the UTC trainings, as well as testimonials
of trainees who are at the same time also service providers. Using this App and
website will be entirely voluntary and the users can stop at any time during the
page browsing process.
As used in this Privacy Policy,
“Personally Identifiable Information” means any information that may be used to
identify an individual, including, postal address, telephone number, fax number
and e-mail address among others.
On the website/App there will be a
general contact section and in case the user wish to give any personal feedback
or submit and inquiries, the user will be asked to provide PII under those
circumstances when using the app or website, so that the website/App team can
contact the user. The PII will not be shared with any other party and is only
to be used by the team to contact the user.
In general, the website and App
generates “Anonymous Information” means information that is not Personally
Identifiable Information. They do not enable identification of an individual
user, such as aggregated information about the use of the App and its services
or reports that collect information about numerous users without identifying a
particular user.
The Huru Team will not share your
data or content with anyone without the user’s consent and only to the extent
necessary to provide the user with the products and/or services requested.
There will be no information collected about the user from other sources
outside of the user’s interaction with the App or when the user calls a phone
number of services listed on the Website/App.
The content of the messages
provided by the users in the general feedback/inquiry section will be reviewed
once in a while by the Huru team and will be worked upon. The messages will be
stored and these messages will only be accessible to the Huru team.
The Huru team will not sell or
otherwise transfer data or content of users to advertising platforms, data
brokers, information resellers, or any other third-party organizations.
Additionally, the team will not
use user’s data or content for advertising, marketing or similar services.
The Huru team does not collect any
Personally Identifiable Information from the user on the App and website unless
the user voluntarily chooses to disclose such information in the
feedback/inquiry section. At a later stage of the App/website development there
may be a chat function (with the team) available that will ask for PII in order
to be able to contact the user. In order to improve the quality of the
App/website Anonymous Information may be asked by the users in aggregate from
to build the quality and more useful services such as by performing statistical
analyses of the collective characteristics and behavior of users to personalize
their experience on the website/App. However, the team does not foresee this
function to be available for the piloting phase.
Anonymous Information may also be
provided to affiliated organizations such as ACFR, UNODC and MoHCDEC. There
will be a separate terms of reference provided on this data and such data will
not be charged by the team. These parties will agree to process such
information in compliance with this privacy policy and the Huru Team will limit
their use of
such information and to use other
appropriate confidentiality and security measures to ensure the protection of
the users who will mainly be part of vulnerable populations such as people who
are affected by substance use disorders.
The Huru Website/App is not
attempting to provide any type of health advice or analysis to users. The
Website/App is simply presenting users with information regarding substance use
and and available evidence-based treatment centers. Users should not interpret
the App’s display of this data as any type of assessment from it. The Huru
Website/App is not responsible for any assessment or decision users make based
on the data presented in the Website/App or the services of any provider listed
on the Website/App.
The user can direct the team to
share data with other parties when providing feedback. This data may then be
governed by third-party privacy policy such as Google analytics.
Some options of the App/Website
may allow the user to share information with others, such as leaving comments
relating to a blog post. Remember that when the user shares information
publicly, it may be indexable by search engines. Do not share information that
you do not want to be made public.
Some of the App’s/Website’s pages
may utilize “cookies” and other tracking technologies like pixel tags and web
beacons to improve the functionality of the App/website. Cookies are text files
that are sent by servers to web browsers and stored on your computer.
They tell the team which parts of
the Website the user has visited so they can alert the team to software
compatibility issues and save the user’s preferences for future visits to the
App.
Web beacons and pixel tags are
images embedded in a webpage or e-mail for the purpose of measuring and
analyzing usage and activity. The Website, or third-party service providers
acting on behalf of the Huru App/Website, may use web beacons and pixel tags to
help the team analyze usage and improve the App’s/Webiste’s functionality. Some
cookies and other technologies may serve to recall PII previously provided by a
user.
The user may be offered a browser
that has a “Do Not Track” option, which allows the user to signal to operators
of websites and web applications and services (including behavioural
advertising services) that the user does not wish such operators to track
certain online activities over time and across different websites. At this
time, the Huru App/Website will not support Do Not Track requests which means
that the App/Website will collect
information about the user’s
online activity while the user is using the Huru App/Website. The App/Website
does not collect online activities after the user leaves the App/Website.
The Huru App/Website may contain
links to third-party websites. They will be revised and approved by the Huru
Team.
The Huru Team wishes to inform
users of the App/Website to use third-part links and websites with caution, as
this privacy policy does not apply to such websites. Using these links is at
the user’s own risk and the Huru Team reminds all users to review the website’s
terms of service and privacy policies when visiting such sites. The Huru Team
does not
monitor or have any control over
and make no claim or representation regarding third-party websites. To the
extent such links are provided by the App/Website these do not imply the Huru
Team’s endorsement, adoption or sponsorship of, or affiliation with, such
third-party websites. When the user leaves the Huru App/Website to use
third-party links and websites, the terms of this privacy policy no longer
applies.
The privacy and security of user
data is important to us. We maintain physical, electronic, and procedural
safeguards that are designed to control and protect your data from unauthorized
access. We adhere to accepted industry privacy standards. Our used data
protection measures include data encryption, strong user authentication, data
backup and data erasure.
In addition, The Huru Team uses
encryption and a protocol for transmitting private information via the
Internet. Unfortunately, no maintenance of data or transmission over a public
network such as the Internet can be guaranteed to be secure. Therefore, while
the Huru Team follows accepted industry standards and implement reasonable
security practices to protect PII, that are in line with European Union’s
standard data protection (GDPR), which are commonly used in Tanzania, its
absolute security cannot be fully guaranteed, however, as the protection of all
Huru App/Website users are of utmost importance, the Huru App will make sure to
inform all users once changes are effective.
As previously mentioned, the Huru
App may update the Privacy Policy in line with the developmental stages of the
Huru App/Website. In the event of a change, the Huru Team will notify the user
when the new privacy policy is available, directly on the App by using a Push
Notification function or a pop up function. The Huru Team advises all users to
review this Privacy Policy periodically for any changes.
This Privacy Policy applies only
to information collected through the Huru App/Website and does not apply to
information collected offline through other communication mediums. This policy
does not apply to employment-related information, including information received
from job applicants.
Currently the Huru Team is using
Google Analytics to understand the Huru App’s/Website’s audience and how to
tailor the content of the App/Website to best serve the user’S needs. No
Personally Identifiable Information is collected by Google Analytics.
Specifically, Google analytics collects data about how the user uses the
app/website which are time of visit, pages visited, and the time spent of each
page of the webpage.
As a user of Huru App you have
the following rights which are as stipulated in the consumer protection
regulations in the Tanzania Communications Regulatory Authority (TCRA)
Electronic and Postal Communication Regulations:
(a) fairly and lawfully
collected and processed;
(b) processed for identified purposes;
(c) accurate;
(d) processed in accordance with
the consumer’s otherrights;
(e) protected against improper
or accidental disclosure; and
(f) not transferred to any party
except as permitted by any terms and conditions agreed with the consumer, as permitted by any permission or approval
of the Authority, or as otherwise permitted or required by other applicable laws.
The following articles of the EU
GDPR are used as basis and guidance in developing data handling strategy and
privacy polics of the Huru App/Website:
(a)
The right to be informed which will be through the Privacy Policy
(Article 12);
(b)
The right to access which will have subject access request form (Article 15);
(c)
The right to rectification (Article 16 and Article 5 (1) (d));
(d)
The right to be forgotten (Article 17);
(e)
The right to restrict processing (Article 18);
(f)
The right to data portability (Article
20);
(g)
The right to object (Article 21)