Privacy Policy — Genesis Study App

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Privacy Policy — Genesis Study App

Last updated: September 11, 2026

This Privacy Policy applies specifically to the mobile application “Genesis Study” (package/bundle ID: it.coehar.genesisstudy), available on Google Play and the App Store, developed on behalf of the GENESIS clinical trial.

1. Data Controller

The data controller for the Genesis Study app is:

ECLAT SRL Via Santa Sofia 89, 95123 Catania, Italy Email: diasmoke@eclatrbc.it

ECLAT SRL operates in connection with CoEHAR (Center of Excellence for the Acceleration of Harm Reduction, University of Catania), the scientific coordinator of the GENESIS study.

2. What This App Is For

Genesis Study is the participant-facing companion app for a 12-month randomised, double-blind, controlled, international multicentre clinical trial comparing changes in cigarette consumption after switching to high or low nicotine strength e-cigarettes, in smokers with Schizophrenia spectrum disorders. The study runs at sites in the UK and Italy.

3. Data We Collect

Through the app, we may collect and process:

  • Account/registration data: participant identifier assigned within the study (no direct identifiers are stored in the app itself; data is pseudonymised).
  • Health diary and study data: self-reported information on cigarette/e-cigarette consumption, symptoms, and other data points required by the clinical trial protocol.
  • Step count / activity data: on iOS, the app uses Apple HealthKit to read step count, shown on the Health Diary and Report screens, with the user’s explicit permission.
  • App info and performance data: technical/diagnostic data (e.g. crash logs, device information) used to keep the app working correctly.

We do not share this data with third parties for advertising or marketing purposes.

4. Why We Process This Data

Data is processed solely for the purposes of conducting the GENESIS clinical trial, in line with the study protocol approved by the relevant ethics committees, and under the legal bases of:

  • explicit consent given by the participant when enrolling in the study, and
  • scientific research purposes as permitted under applicable data protection law (including Regulation (EU) 2016/679 — GDPR, for EU/EEA participants).

5. Data Sharing

Study data collected via the app may be shared, in pseudonymised form, with:

  • the study’s research team and investigators at the participating clinical sites;
  • regulatory or ethics bodies, where required by law or for audit purposes.

We do not sell participant data, and we do not share it with third parties for commercial purposes.

6. Data Retention

Data is retained for the duration of the clinical trial and for any additional period required by applicable research, regulatory, or archiving obligations, after which it is deleted or fully anonymised.

7. Security

We apply appropriate technical and organisational measures to protect participant data, including encryption of data in transit.

8. Your Rights

If you are a participant in the EU/EEA or UK, you have the right to access, correct, or request deletion of your personal data, and to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal. To exercise these rights, contact diasmoke@eclatrbc.it.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected on this page with an updated “Last updated” date.

10. Contact

For any questions about this Privacy Policy or about the Genesis Study app, please contact: info@eclatrbc.it