Last updated: 10th January, 2020

This Privacy Policy sets forth our policy in relation to personal and other information collected from Users and Practitioners of the website https://www.wazima.health and https://www.wazima.africa.com (the “Websites”). All personal data will be held and used in accordance with the GDPR and any relevant national laws which implement the GDPR and any legislation that replaces it in whole or in part. We are registered under the Data Protection Act, Registration Number ZA441358

This Privacy Policy is the integral part of the Terms of Use, Terms and Conditions for Practitioners (collectively, the “Terms”) and governs collection, processing and use of your personal and certain other information.

All capitalized terms used in the Terms shall apply to this Privacy Policy with the same meanings as in the Terms.

By browsing, accessing and using our Website and Services, you agree to proceed on the basis of this Privacy Policy and you agree with the conditions of processing the personal information contained in this document.

GENERAL PROVISIONS

Providing personal information is an act of trust and something which we take seriously. Unless given consent to do otherwise and/or otherwise permissible by and/or required by law, Wazima Health will only collect and use personal information as set out below.

Throughout this Privacy Policy, we refer to your “personal information” which is any information relating to you that can identify you, directly or indirectly, in particular by reference to an identifier such as a name, email address, an identification number, location data, or an online identifier.

We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland to which the GDPR applies.

PERSONAL INFORMATION THAT WE COLLECT

Wazima does not collect personal information beyond the limited data we need for you to use our services on the Website.

Wazima collects personal information provided directly by the User or Practitioner when the User or Practitioner registers an account, performs any activities and transactions on the Website and uses our Services. We may receive the following personal information:

* information provided during account registration, including, without limitation: personal details, user name, address, phone number and email address;

* health and medical information: information about health, symptoms, treatments, consultations and sessions, medications and procedures;

* gender;

* financial information provided during transactions, including, without limitation, bank account numbers;

* location data;

* any other personal information which you directly provide to Wazima; and

* any other personal information requested or required by the Website.

We may also automatically collect certain information about User’s or Practitioner’s computer device, browsing activities, statistical information, information on visits and use of the Website and Services. We may receive certain data automatically collected by our software, for example: IP address, cookies data, performance specifications of the User’s or Practitioner’s hardware and software, date and time of access to the Website, the URL of the page requested. This information is aggregated to provide statistical data about our Users' or Practitioner’s browsing actions and patterns, and does not personally identify individuals.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract and “legitimate interests”.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer at [email protected]. Please title your email as “DPO”.

HEALTH AND MEDICAL INFORMATION

The main type of information we hold about you is health and medical information: information about User’s health, symptoms, treatments, consultations and sessions, medications and procedures. We may receive such information as a result of User’s consultations with Practitioners, and interactions with our digital services, or any other use of our healthcare services. All health and medical information is held securely in accordance with our data retention rules.

We may also hold information about you and your health from other apps, devices and services where you have given your consent to that data being shared with us.

YOUR DEVICE AND LOCATION

When you visit or leave our Website, we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings.

USE OF PERSONAL INFORMATION

Personal information will be collected, held, used and disclosed for the following primary purposes jointly and/or severally:

* for the purposes for which it was collected (as set out in this Privacy Policy);

* to provide you with Services requested, complete your transactions, and address your inquiries;

* to use your medical information to provide you with healthcare or treatment;

* to give you a medical diagnosis;

* to identify you and personalize your experience with us;

* to process registration and log in to the Website;

* to facilitate our communication and contact you about our Services or other matters;

* to provide you with newsletters via mail and e-newsletters;

* to process any requests, complaints and applications;

* to record statistical data for marketing analysis and to conduct market research;

* to share personal information with our healthcare practitioners and other trusted third parties in the manner described below;

* to the extent permissible or necessary by law, for any other purpose as may be deemed reasonably necessary by Wazima in the circumstances;

* to perform other activities as described in the Privacy Policy.

We also store your medical information, such as notes from consultations, recordings of our consultations with you and your interactions with our digital services, for safety, regulatory, and compliance purposes. We may need to disclose certain information in compliance with reasonable requests by regulatory bodies including the General Medical Council, MHRA, and Care Quality Commission, or as otherwise required by law or regulation.

Where necessary for safety, regulatory and/or compliance purposes, we may audit consultations and your other interactions with our services. Strict confidentiality and data security provisions will apply at all times to any such audit and access.

The personal information is available and accessible by our employees who we believe reasonably need to come into contact with that information to provide services or in order to do their jobs. Wazima uses all necessary means to monitor and limit the administrative access to personal information of the Users and Practitioners.

COOKIES AND OTHER TECHNOLOGIES

Wazima Health uses “cookies”. A cookie is a small text file that is placed on your device by websites that you visit. Typically, cookies are stored on your computer’s hard drive. We use cookies to enable Website systems to recognize your device, to provide certain features, to analyze traffic and user experience, and to improve the quality of our Services.

We do not disclose any information received with the use of cookies except for our Service Providers (see definition below). Thus, we may use certain third party services, such as Google Analytics and Inspectlet that help us to analyze usability and user experience. These Service Providers may place their own cookies in accordance with their own Privacy Policies that we do not own or control. Wazima shall not be responsible for such Service Providers.

You can control cookies through your browser settings and other tools. You may change your web browser’s settings to stop accepting cookies, to enable your browser notify when you receive new cookies, or to prompt you before accepting a cookie from a website you visit. However, because cookies allow you to take advantage of some of our essential features, we recommend that you leave them turned on. For instance, if you block or otherwise reject our cookies, you may not be able to use our Website or Services entirely.

DISCLOSURE OF THE PERSONAL INFORMATION

The protection of the personal information and your privacy is important to us. We do not disclose the personal information to any third parties except on a limited and strict need to know basis when we need to disclose such information to:

* Practitioners, pharmacies and other service providers engaged by us to perform some functions on our behalf on a confidential basis;

* legal and regulatory authorities;

* our employees.

We may share the minimum amount of your personal data with companies we have hired to provide services on our behalf, including those who act as data processors on our behalf, acting strictly under contract in accordance with Article 28 GDPR. Those data processors are bound by strict confidentiality and data security provisions, and they can only use your data for the relevant purposes in the ways specified by us. Those we share your information with are not allowed to use it to try to sell their own services to you.

Wazima Health will not sell your information to anyone for any reason. We will only send you information about our own products and services, and those of group companies and selected partners if you have given us permission to in accordance with this Privacy Policy. Please be informed that if you choose not to receive this information, you may miss our offers and deals.

Where you access our services through your health insurance provider, and where you have given your consent, we will need to let your insurance company know your name, email address, policy number, location (based on IP address), demographic information, that you had an appointment with us, the date of the appointment, details of your diagnosis, prescription, pharmacy location, whether or not you had a referral made and other similar information about your appointment with us. 

We will, where necessary for your treatment or care, share your information with your other health and social care providers.

We can only speak for ourselves; this Privacy Policy does not apply to the practices of Service Providers and other third parties that we do not own or control, or individuals that we do not employ or manage.

THE RIGHT TO EDIT PERSONAL INFORMATION

You may access your personal information held by us to correct, update and remove inaccurate or incorrect data. You have the following rights:

• delete some or all personal information that we hold about you;
• change or correct your personal information which we hold about you;
• object to, or limit or restrict, use of your personal information;
• right to access and/or take your personal information: you can ask us for a copy of your personal information and can ask for a copy of personal information you provided in machine readable form.

If you want your personal information to be corrected, updated or removed, please contact our customer support or send us your email at [email protected] Please provide us with enough information to identify and verify you in your written request, and allow 30 days for this request to be processed. We may collect the fee as provided by law.

SECURITY

We use certain technologies to ensure the confidentiality of your personal information and to secure your sensitive data. Wazima uses several security measures, including Socket Layer protocol (SSL), Encryption, Secure password requirements, Advanced security monitoring, Malware prevention, Extended Validation SSL Certificate which are industry-leading technologies to ensure that your information is fully encrypted.

However, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

ACCURATE INFORMATION

You are responsible for maintaining the accuracy and completeness of your personal information. You shall inform us in relation to any changes to your personal information.

DATA RETENTION

We retain your personal information while your account is in existence or for as long as it is necessary or your user account is active or as needed to provide you with the Services on the Website or as provided by the applicable laws. The data retention of your medical records is provided by the Department of Health (2006) Records management: NHS code of practice, and summary guidance issued by the British Medical Association. 

As required by applicable law we retain information as follows:

• Communications online if recorded are stored for 3 months in case of dispute between the User and a Practitioner, thereafter it is deleted if there is no dispute within this period;
• GP records are retained for 10 years after death or after the patient has permanently left the country unless the patient remains in the European Union. In the case of a child, if the illness or death could have potential relevance to adult conditions or have genetic implications for the family of the deceased, the advice of clinicians should be sought as to whether to retain the records for a longer period. Electronic patient records (EPRs) must not be destroyed, or deleted, for the foreseeable future.
• Maternity records are retained for 25 years after the birth of the last child.
• Records relating to persons receiving treatment for a mental disorder within the meaning of mental health legislation are retained for 20 years after the date of the last contact; or 10 years after the patient's death if sooner.

If you no longer want us to use your personal information to provide you with the Services, you may close your account. However, we may retain and use your personal information as necessary to comply with our legal obligations and resolve disputes.

MERGE OF COMPANY

If Wazima merges with, or is acquired by, another company or organisation, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser or any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

CROSS-BORDER DATA TRANSFERS

We process information both inside and outside of Designated Countries and rely on legally-provided mechanisms to lawfully transfer information across borders. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

NOTIFICATIONS

From time to time we may send you messages that are service-related and required for our Users and Practitioners, including newsletters and other alerts. We may also send you email relating to your personal transactions, about special promotions, featured investments and other news of the Website and Services. We may also send you news and updates about changes to our Website and Services.

We would like to get in touch with you, by post, email and text message, about products and services which we, our group companies and selected partners provide and think you would be interested in, and to let you know about relevant offers and news. We will only do this if you have given us permission (you must tell us if you want to receive this information). If you no longer want to receive marketing information in a particular way, or receive any marketing at all, you can change your mind at any time. You can change your preferences by logging into ‘Your Account’ or visiting www.wazima.health or www.wazima.africa.соm. You can also unsubscribe from further emails by clicking on the unsubscribe link at the end of every email we send you.

MODIFICATIONS TO THE PRIVACY POLICY

We may revise the Privacy Policy at any time and in our sole discretion by posting the relevant revised Privacy Policy on the Website. By continuing to use our Website and Services, you agree to be bound by the revised Privacy Policy.

DATA PROTECTION OFFICER

To communicate with our Data Protection Officer, please contact us at [email protected].