DATA PRIVACY

Data Privacy

Kihmarl Services Limited (“We” or “Us”, as the context may be) are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) (“Privacy Policy”) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The purpose of this policy is to give you confidence as you visit and use the www.eazicare.com.ng and/or our app (“Site”), and to demonstrate our commitment to fair information practices and the protection of privacy. This policy is only applicable to this Site.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using the Site you are accepting and consenting to the practices described in this Privacy Policy. If you do not understand any aspect of our Privacy Policy, please feel free to contact using the information found at the end of the Privacy Policy.

For the purpose of the Data Protection Act 1998, the data controller is Kihmarl Services Limited of Maria Assumpta House, Km39, Lagos-Ibadan Expressway, Aseese, Ogun State, Nigeria.

This version was last updated on 2 July 2018.

European Union General Data Protection Regulations (GDPR)

The data protection law in the European Union (“EU”) changes on 25 May 2018. From this date onward, requests made by you under the data protection law applicable to us where you reside will be attended to by us in accordance with this Privacy Policy and the said data protection law.

Under 18 Years of Age

Our Site is not eligible for use by persons under 18 years of age without legal parental or guardian consent. No one under age 18 may provide any personal information to or on our Sites without legal parental or guardian consent. We do not knowingly collect personal information from persons under 18 if such information is provided without legal parental or guardian consent. If you are under 18, do not use or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use without legal parental or guardian consent. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18 for which there is no legal parental or guardian consent, please contact us.

Information we collect from you

We will collect and process the following data about you:

  • Information you give us. This is information about you that you give us by filling in forms on our the Site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Site, subscribe to our Services, carry out an appointment with a Platform Doctor and when you report a problem with our Site.
    • Identity Data includes first name, last name, address, username or similar identifier, marital status, title, date of birth and gender. In certain circumstances, it may also include your Emirates ID number and/ or copy, Passport number and/or copy, Nationality, place of work and work ID number.
    • Contact Data includes billing address, delivery address, location, email address and/or telephone numbers.
    • Photos or other data uploaded onto our Site by you
    • Communications with us via social media platforms, email, electronic messages and other electronic and non-electronic communications;
    • Your networks and connections made available to us, depending on the permissions you have granted, from your mobile and desktop devices’ address book contacts, and other social media such as Facebook, Instagram, and Twitter.
    • Financial Data includes bank account and payment card details, payment history.
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    • Sensitive medical data (which may include your medical history, health status and testing results, and any other non-public health information ).
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
  • Information we collect about you. With regard to each of your visits to our Site we may collect the following information:
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    • Health information about you prepared by the Platform Doctors who provide the Services through the Site such as medical records, treatment notes, and other health information;
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, make and model (mobile phones only), operating system, hardware version, platform, device settings and other technology identification on the devices used to access our Sites, file and software names and types, device identifiers, time zone setting and location, device locations such as through GPS, Bluetooth or WiFi signals, browser plug-in types and versions, operating system and platform, connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Sites, how you use your devices to access our Sites, including the screens you visit
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    • Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or from third parties (including any third query party links to to our Site). In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on our Site. We will also have told you for what purpose we will share and combine your data;
  • Information obtained from video consultation. You consent and authorize us to audio record, video record, and/or still photograph your consultation. All recordings, videos or images will become part of your electronically stored record. Specifically in respect of users in the UAE, we disclaim any obligations with respect to confidentiality and security in situations relating to (i) transfer of any of your information and data that was previously stored from different sources (such as information in the medical records, and review of radiology imaging) or (ii) transfer of your medical investigation reports and diagnostic imaging to a Health Services Provider in relation to their drafting of any pathology report about you.
  • Aggregated data. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
  • We do not collect the following Special Categories of Personal Data: your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership. Nor do we collect any information about criminal convictions and offences.

How is your data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data, Contact Data, Transaction Data, Profile Data, Financial Data, Health Information and Marketing and Communications Data by using our Site filling in forms or by corresponding with us by phone, email, in person or otherwise. This includes personal data you provide when you
    • purchase a Service
    • use the Service with a Platform Doctor
    • create an account on our Site
    • request marketing to be sent to you;
    • enter a competition;
    • give us feedback or contact the support team
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Cookies

Cookies are small computer files that are transferred to your computer’s hard drive that contain information such as user ID, user preferences, lists of pages visited and activities conducted while browsing the Site. At your option, expense and responsibility, you may block cookies or delete cookies from your hard drive. However, by disabling cookies, you may not have access to the entire set of features of this Site. Our Site uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our services.

Location Information

You can choose whether or not to allow our Sites to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of our Sites may then be inaccessible or not function properly.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Links to Third Party Sites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

How we use your personal data

We will only use your personal data when the law allows us to. We use information held about you in the following ways:

  • to carry out our obligations to you and to provide you with the information, and medical or other services that you request from us including treatment, payment and health care operations:
    • We keep a record of the health information you provide us including test results, diagnoses, medications etc. which we may disclose to laboratories and doctors;
    • We keep a record of the services and supplies you receive when we are providing care to you so that this information can be used for billing purposes;
    • We may use your health information to review our services and to evaluate the performance of the Platform Doctors carrying out the Services;
  • to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
  • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail, SMS or push message, ) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new user, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
  • to notify you about changes to our Service;
  • to ensure that content from our Site is presented in the most effective manner for you and for your computer.
  • to administer our Site for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our Service, when you choose to do so;
  • as part of our efforts to keep our Site safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them.
  • to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email, text message or other means. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your data

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer/user (a) Identity
(b) Contact
(c) Profile
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
To process your purchase including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) communicate with you about our products and services and respond to you when you contact us
(d) managing your queries through our Customer Service team – this may include recording calls to our teams.
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and the Sites (including troubleshooting, improvement, data analysis, testing, system maintenance, security, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To deliver better and more personalised Site content so that you have a beneficial and valuable experience when using our Sites, products and/or services (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Performance of a contract with you
To enable you to utilize a feature of a product or service provided to you. (a) Identity
(b) Contact
(c) Profile
(d) Health Information
Performance of a contract with you
To provide to your insurance company/ies who may contribute to the cost of the products or services you request to use (a) Identity
(b) Contact
(c) Health Information
Necessary to comply with a legal obligation
To provide to your other healthcare providers such as another clinic/ healthcare service provider (a) Identity
(b) Contact
(c) Profile
(d) Health Information
Performance of a contract with you
To use data analytics to improve our Sites, products/services, marketing, customer relationships and experiences (a) Identity
(b) Technical
(c) Usage
(d) Transaction
(e) Special Categories of Personal Data
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Sites updated and relevant, to develop our business and to inform our marketing strategy)
(b) Necessary to comply with a legal obligation
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
Any other purpose disclosed by us when you provide the personal data As applicable (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation

Marketing

We will always give you the option to choose not to receive marketing communications from us.

If you do not wish to have your personal data used by Us to promote our own or third parties’ products or services, you can opt-out by contacting us. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to information provided to the Us as a result of a product or service purchase, product service experience or other transactions.

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by contacting us.

Promotions

We may use your Identity, Contact, Technical, Usage and Profile Data and Special Categories of Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or created an account or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party Marketing

We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Marketing Opt Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Disclosure of Your information

You agree that we have the right to share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may disclose your personal information to:

  • contractors, health care professionals, which may include nurses and physicians, service providers, business associates, our staff and any third parties we use to support our business and to provide health care services;
  • advertisers that require the data to select and serve relevant adverts to you and others;
  • analytics and search engine providers that assist us in the improvement and optimisation of our Site;
  • other Service providers, health plans, or their related entities for their treatment or payment activities, or health care activities;
  • third parties in the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets;
  • third parties if Kihmarl Services Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  • third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, regulation, subpoena, court order, legal process or government request or in order to enforce or apply our terms of use (www.kihmarl.com/terms-of-use) and other agreements; or to protect the rights, property, or safety of Kihmarl Services Limited, our customers, or others.
  • third parties when we believe in good faith that disclosure is necessary to protect your safety or the safety of others, to protect our rights, to investigate fraud, or to respond to a government request;
  • third parties to notify or assist in notifying a family member, personal representative or another person responsible for your care of your location and general condition.

You further agree that we may make your patient notes (created by a doctor during a Kihmarl TeleMed consultation) available to any and all other doctors and clinics on the Kihmarl TeleMed platform.

International Transfers

We may share your personal data within the Kihmarl TeleMed platform. This may involve transferring your data outside the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.

External third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in Europe. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy shield which requires them to provide similar protection to personal data shared between Europe and the US.

Where we store your personal data

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

We store all your personal health data – including your primary care information, secondary care information, medication information and diagnostic information – on secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We do not store any credit or debit card information. Payments are processed via a third party payment provider that is fully compliant with Level 1 Payment Card Industry (PCI) data security standards. Any payment transactions are encrypted using SSL technology.

Once we have received your information, we will use strict procedures, industry standard physical, technical and administrative safeguards and security features to try to prevent unauthorised access.

Protection of Passwords

Your account is protected by your account password, and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use.  It is your responsibility to control the dissemination and use of your password, and to control access to and use of your user ID and password.  If you need to deactivate your account, promptly inform us.  You agree to promptly notify us of any unauthorized use of your username, password, or any other breach of security that you become aware of.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This includes the legal directives specified by the Nigerian Ministry of Health as the medical regulator.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Rights

You have the right to make the following requests at any time:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Nigerian Ministry of Health regulations will always be followed in this instance.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise the right at any time by contacting us at info@kihmarl.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

You may also request that a copy of your information be provided to another person.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to our Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Continued use of our Site following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. By using the Site, you are agreeing to our collection, use and disposal of you personal information and other data as described in this policy, both as it exists now and as it is changed from time to time. Please check back frequently to see any updates or changes to our Privacy Policy.

Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to connect@eazicare.com.ng

Kihmarl Services Limited, July 2018