Qina LDA Operations
Qina offers business-to-business and direct-to-consumer programs. For the purposes of this document, services include:
- Participating in remote research studies using a telehealth platform and digital tools
- Participating in a research program that includes nutrition coaching, behavioral support, access to a tracking app, and incentives & rewards
The nature of the service may involve conducting a remote research study approved by an independent ethics committee, or it may involve evaluating the program by examining specific aspects such as client satisfaction. In both cases, participant data is collected, analyzed, aggregated, and reported.
Participation
Participation in either a research project or program evaluation is entirely voluntary. All participants will be notified via email whether they have been successfully included in a study.
Data
Where data is used for research or program evaluation, all data will be de-identified and aggregated prior to analysis. Data is coded and tagged by experts to ensure it is in the appropriate format for analysis.
Participant data may include: answers to questionnaires, data from wearables, de-identified chats with a dietitian, and medical notes in the electronic health record. All data is anonymized and de-identified in accordance with ICO rules.
Incentives & Rewards
- As part of research study tasks, participants may be required to use a wearable device, an app, or a specific product. These tools will be provided free of charge. There is no cash remuneration; however, participants will receive access to nutrition coaches.
- For a metabolic health/GLP-1 program, participants may be recommended to purchase a specific tool, for which they will receive a discount voucher upon achieving a designated milestone.
Partners & Collaborators
To deliver research or evaluation projects, we may work with partners responsible for specific aspects of each project, such as recruitment, data analysis, and more. The nature and requirements of each project will determine the composition of the project team. Collaborators and partners may include clinical labs, practitioners, diagnostic test providers, data scientists, universities, and others. The specific partners and their roles will be outlined in the consent form for each project.
Privacy & Confidentiality
Your data is collected and securely stored in our repositories. All processing is conducted in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). Qina LDA, as a Portuguese entity, is also subject to applicable national data protection law. Where obligations conflict, the standard providing the highest level of protection to participants will apply. We comply with all ICO recommendations and rules.
Data Minimization & Pseudonymization
Only data directly relevant to the study objectives and delivery will be collected. At screening, each participant will be assigned a unique alphanumeric study ID. All research data will be linked to this study ID rather than to personal identifiers wherever practicable. A list linking personal identifiers to study IDs will be stored separately from the research dataset in the trial master file, hosted by the study sponsor and accessible only to authorized personnel for safety monitoring or audit purposes.
Participant contact details — including name, email address, telephone number, and home address — will be shared with relevant study partners solely for study-specific tasks such as blood draws or physical measurements. These disclosures are made for logistical purposes only and do not constitute research data sharing.
The parties will collect and process only those categories of personal data necessary for the agreed purposes of the study. Shared personal data must not be irrelevant or excessive relative to those purposes. Shared personal data will be processed only for the following purposes, and in no way incompatible with them:
- Conducting and managing the study
- Supporting participant recruitment, screening, and communication
- Enabling data collection, analysis, and reporting
- Ensuring participant safety and compliance with applicable regulatory requirements
Data Security
Platform
Qina uses SANNO Health Ltd, a purpose-built decentralized clinical research platform, for electronic informed consent and data collection. SANNO meets the requirements of ICH E6(R3) for electronic systems used in clinical research. The platform maintains secure, unalterable audit trails capturing every data change, including user identity, timestamp, and modification detail. Aligned with 21 CFR Part 11 and EU Annex 11, SANNO enforces role-based access controls, cryptographic record integrity, and archiving. Electronic signatures are permanently linked to the signing user and timestamp and cannot be altered post-signature. SANNO incorporates the following features relevant to the consent process: a full audit trail of all consent actions, timestamping of every consent event, immutable logging ensuring no consent record can be altered post-signature, and encrypted data storage.
Participant Rights & GDPR
Participants will be informed of the following rights in the Participant Information Sheet and Informed Consent Form:
- The right to access information about how their data is being used at any time during the study
- The right to withdraw from the study at any time without penalty or loss of entitled benefits
- The right to ask questions about data handling and to receive a clear response from the research team
Participants who withdraw will not have previously collected data deleted, as retention is necessary to maintain the integrity of the research record and to satisfy regulatory requirements.
Qina or its partners will conduct a Data Protection Impact Assessment (DPIA) prior to the commencement of any study, in accordance with Article 35 UK GDPR. An external Data Protection Officer (DPO) will be appointed for each study. Contact details are available from Qina upon request.
Data Retention & Sharing
All study or evaluation records obtained throughout each project — including informed consent records, adverse event logs, and trial master file documents — will be retained pseudonymously for 10 years following the end of the study. All data and documents will be archived in an access-restricted, secure organizational folder, accessible only to authorized personnel.
After 10 years, Qina will either anonymize and retain the study data or securely delete it where anonymization is not feasible.
For any questions or concerns, please contact the team at [email protected].
