Privacy policy

This Privacy Policy (the “Policy”) describes practices of Biogen Inc., its subsidiaries, affiliates, and agents (collectively, “Biogen”, “we”, “our”, or “us”) in connection with information we collect, use, and disclose through a cognitive health study called “Intuition” (or the “Study”) presented by Biogen, in collaboration with Apple Inc. (“Apple”), featuring a mobile application (the “Study App”) used with the Apple Watch and iPhone and a Study website, www.intuitionstudy.com, (the “Study Website”).

The Study combines sensor, health, and usage data to allow participants to complete certain thinking and memory activities, respond to surveys, and receive notifications about cognitive health activities. This Study is available to residents of the United States who meet certain criteria for participation and have agreed to the “Informed Consent Form” (or “ICF”) for the Study. This Policy describes the collection, use, and/or disclosure of all data and/or information collected or accessed by the Study (called “Intuition Data”). Intuition Data includes “Study Data” as defined in the ICF. Participants will be emailed a copy of their signed ICF and can also view an unsigned copy of the ICF in the Study App.

By participating in the Study and/or otherwise providing us with your information, you consent to our collection, use, and disclosure (including transfer) of your information in accordance with this Policy. Please do not provide us with any information if you do not accept this Policy.

What types of information do we collect?

We may collect two types of information when you participate in the Study or otherwise access Study-related materials, including through the Study App and Study Website: Personal Information and Non-Personal Information. When this Policy uses the term “Intuition Data”, this includes both Personal Information and Non-Personal Information.

By “Personal Information,” we mean data that is associated with an identifiable individual, such as a name, physical address, phone number, or email address. Personal Information includes, for example, personally identifiable demographic information, mental health or medical information, behavioral or lifestyle survey responses, or medical history information, including information collected through the Study App on your Apple Watch or iPhone and other Study-related activities.

By “Non-Personal Information,” we mean information that is not associated with an identifiable individual. Non-Personal Information may include information which would otherwise be Personal Information, but which has been de-identified or aggregated.

How do we acquire and use your information?

We acquire Intuition Data through your participation in the Study and when you access or seek out Study information, including through the Study App and Study Website.

After you consent to participate in the Study, certain Intuition Data is collected through the Study App including your contact and demographic information, your health and activity information from the Apple Health app, as well as other Study activity information. For example, we collect information about how and when you use the Study App to help us better understand user behavior. The ICF describes the full listing of the categories of Intuition Data that may be collected, used, and/or disclosed as part of your participation in the Study, including information collected through the Study App, as part of enrollment identity verification, survey responses, and other information from virtual visits.

Your Intuition Data will never be sold or used to drive sale of any products. It may be used in accordance with the Terms of Use which may include using the information you share in support of the Study, to adjudicate rewards, to identify and deliver messages that may be helpful to your cognitive health and wellness or otherwise of interest to you.

When you access the Study Website, we may use "cookies" and other technologies such as pixel tags and web beacons. These technologies are used to monitor website activity such as the number of users, their frequency of use, and which parts of the website they have visited. When you visit the Study Website, our servers automatically log your internet protocol (IP) address. The IP address is a unique number assigned to your computer to identify it whenever you are surfing the Web. The IP address is not used to identify or track you personally but is used to maintain communications with you as you move about the Website. While these technologies can tell us when you use the Study Website and which pages you visit, it cannot read data off your hard disk or mobile device. You can set your cookies when you first enter the Study Website by choosing your cookie preferences in the box that appears in front of the webpage. A link is provided at the bottom of the Study Website’s homepage that you can click anytime to bring up the cookie settings box to confirm or change your preferences.

We may collect, use, and disclose your Intuition Data, which includes your Personal Information, for the purposes listed below and, if you choose to participate in the Study, as otherwise described in the ICF:

• providing you and other users with the services and functions of the Study, including setting up the Study App, informing you about Study or service updates, and managing and redeeming the points you accumulate for completion of Study activities;
• to identify and deliver Study-related messages that may be of interest to you;
• to develop and refine the Study, including the Study App and Website;
• to understand overall Study effectiveness and/or its impact on the cognitive health; and
• assisting you with Study-related inquiries and obtaining your feedback.

To whom may we disclose your information and for what reasons?

We may disclose your Intuition Data, which includes your Personal Information, to third parties for certain purposes as described in this Policy. In all cases, we will require the recipient to protect the Intuition Data and use it only for the purpose it was provided, consistent with this Privacy Policy and, if you are participating in the Study, the ICF. We will share your Intuition Data with our Study research collaborator, Apple. However, your contact information and other information that directly identifies you will be separated from the rest of your Intuition Data and replaced with a random code before it is provided to Apple.

We may also share your Intuition Data, which includes your Personal Information, if:

• the recipient has been authorized to provide services on our or Apple’s behalf as part of the Study;
• the recipient is involved in performing, managing, or reviewing the Study, Study activities, Study App, or Study Website, including but not limited to Study staff, Institutional Review Boards or Ethics Committees, government or regulatory authorities, research collaborators, contract research organizations, study monitors, technology partners, etc.;
• the recipient is our or Apple’s service provider who provides us with necessary services, including but not limited to IT services, hosting and maintenance services, organizing of our events, accounting, data analytics services, email messaging services, delivery services, handling of payment transactions, marketing, etc.;
• the recipient is our or Apple’s consultant or professional adviser, including but not limited to accountants, lawyers, and auditors;
• you have specifically consented to such disclosure;
• required by law, such as pursuant to a subpoena, regulatory oversight, or other legal process;
• we believe in good faith that disclosure is necessary (a) to protect our or Apple’s rights, the integrity of the Study, or your safety or the safety of others, or (b) to detect, prevent or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Study, Study App, Study Website, or Intuition Data; and/or

If you participate in, or have questions about, the Study, we may also share your Intuition Data with entities that provide services on our or Apple’s behalf as part of the Study, including vendors such as IQVIA, Inc. (“IQVIA”). IQVIA operates the Study Support Center and will have access to your Personal Information in order to assist you with any questions about your participation. Apple will not have access to any direct identifiers collected by the Study App or Study Support Center. However, if you call the Study Support Center for assistance with issues related to an Apple product (such as technical issues), an AppleCare support number may be provided to you. If you call AppleCare, Apple may have access to certain direct identifiers that you provide to AppleCare, but AppleCare records will not be linked with your Intuition Data. Individuals over the age of twenty-one (21) may participate in the Study and we will not knowingly collect Personal Information from minors under the age of eighteen (18). The Study Website and Study App are not directed to minors, and we request that minors not provide any information through the Website or App. If a minor has submitted information and you would like to request that such information be removed, please contact us as explained below under Study Contact Information section.

How long will my information be retained?

We will retain your Intuition Data collected from the Study Website and Study App only for as long as needed or permitted for the purpose(s) for which it was obtained, as described in this Privacy Policy and the ICF.

How do we protect your information?

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security practices to consider appropriate new technology and methods. We also periodically subject the Study to simulated intrusion tests and have developed comprehensive disaster recovery plans. However, please be aware that despite our best efforts, no security measures are perfect or impenetrable.

What happens if I no longer want to participate?

As stated in the ICF, you are free to change your mind and stop participating in the Study at any time. You can withdraw from the Study through the Study App by choosing “Withdraw from study” in the Profile tab or contacting the Study Support Center at the number listed below. You may also be withdrawn from the Study if you engage in any practices that are found to violate the ICF or Intuition Terms of Use. If you withdraw or are withdrawn from the Study, no additional Intuition Data will be collected about you, however, information that was previously collected about you may continue to be used as described in this Policy and the ICF.

After termination of the Study or if you withdraw or are withdrawn, Biogen and others described in this Policy and the ICF (including Apple) will keep the Intuition Data in accordance with any relevant applicable law or legal guidelines.

Linking to other websites and applications

From time to time, the Study may provide links to other websites or applications, not owned or controlled by Biogen, that we think might complement and enhance your experience with the Study. This Policy applies solely to information we collect through the Study. If you access or use a linked website or application, the privacy policy of that other website or application will apply to your access or use. We encourage you to review each such third party’s privacy statement as well as their terms of use. We are not responsible for the content and privacy policies or notices of those websites or applications.

True Depth API use

The Study App uses the TrueDepth API provided by Apple, which uses the camera for the purpose of tracking eye movements and angle of the face during completion of certain Study tasks, if you choose to allow the collection of this data in the Study App. This data will help the Study learn how head and eye movement can relate to thinking and memory. We may collect, use, and disclose this data as described in the ICF. We will retain the data only for as long as needed or permitted for the purpose(s) for which it was obtained, as described in this Privacy Policy and the ICF.

Study Contact Information

If you wish to contact us, have any inquiries or feedback on this Policy, or need more information on or access to data which you have previously provided to us, email us at privacy@biogen.com or call the Study Support Center at 833-216-0186.

Changes to this Privacy Policy

Biogen may change this Policy from time to time. When updates are made, the version date (located at the bottom of this Policy) will also be updated to reflect that a revision occurred and will be made available in the Study App as well as on the Study Website. The updated Policy will take effect immediately, will supersede all earlier versions, and will apply to Intuition Data provided to us previously. Each time you access the Study Website or Study App and any updates, upgrades, new versions, documentation and content and services provided by or through Biogen, you acknowledge and agree that the latest version of this Policy shall apply.

We encourage you to reread this Policy periodically to see if there have been any changes that may affect you. We will notify you through the Study App of any material changes to this Policy. This Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

Effective Date: February 27, 2023