OKADOC PRIVACY POLICY

Last Updated: 29 March 2020

Effective Date: 29 March 2020

  1. Introduction

Okadoc respects and is committed to protecting your privacy and personal data. This policy will help you understand how we use and protect your personal data which you provide to us and which we collect through our website (www.okadoc.com) or mobile applications (the “Platform”) when you use and access our Platform and our services available on the Platform comprising: (a) a directory of doctors and other healthcare specialists, hospitals and clinics (collectively, “Healthcare Providers”) healthcare services providers in Saudi Arabia, United Arab Emirates, and Indonesia (the “Directory”); (b) a medical appointment booking facility (the “Appointment Booking Facility”); (c) a real live real time video, audio and instant messaging facility for online consultations between patients and healthcare providers (the “Doctor Online Consultation Facility”); and (d) general non specific health tips and blogs for educational and informational purposes (the “Blogs” and together with the Directory, the Appointment Booking Facility, the Doctor Online Consultation Facility and the Blogs and such other services we may provide on or from the platform from time to time the “Services”). if you have any questions, feel free to contact us at help@okadoc.com.

This Privacy Policy sets out the basis on which any personal data we collect from you or other sources or that you provide to us (“Personal Data”) will be processed by us in connection with your access and use of the Platform and the Services. We understand the importance you place on the Personal Data, and we are committed to protecting and respecting your privacy. Please read the following carefully to understand our practices regarding your Information. By using our Platform and Services, you agree to the handling of your Personal Data in accordance with this Privacy Policy.

References in this Privacy Policy to “we”, “our” or “us” (or similar) are references to Okadoc Technologies FZ-LLC, Dubai Healthcare City, Building 47, office 302, Dubai, UAE or one or more of our affiliates. References to “user” or “you” (or similar) are references to you as an individual or legal entity as the case may be.  If you have any queries in relation to our Privacy Policy or your Personal Data please contact us at help@okadoc.com.

We keep our privacy policy under regular review. This version was last updated on March 29, 2020. Our business changes constantly, and our Privacy Policy may therefore also need to change. We will post the current version of this Privacy Policy on the Platform and each such change will be effective upon posting on the Platform or upon the date designated by us as the “effective date”. We may e-mail periodic reminders of our notices and conditions, but you should check our Platform frequently to see recent changes.  It is your obligation to regularly check the Privacy Policy. Your continued use of the Platform following any such change constitutes your agreement to this Privacy Policy as so modified.

 

In addition, healthcare providers and other third parties who have registered and entered into a subscription agreement with us in relation to our appointment booking facility available on the Platform, will be subject to an additional provisions as to how we will use Personal Data as set out in such separate agreements.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you use our Platform and Services, you consent to the collection, use and sharing of your personal data under this Privacy Policy (which includes all other documents referenced in this Privacy Policy) and agree to the Terms of Use for the Platform. We created this Privacy Policy to give you confidence as you use the Platform and Services and to demonstrate our commitment to the protection of privacy.

The Platform may include links to third-party websites, plug-ins and applications including those of Healthcare Providers. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and applications and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy notice of every website and application you visit.

  1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Dataincludes first name, last name, date of birth, gender;
  • Contact Data includes email address and/or telephone numbers;
  • Healthcare Provider Data includes (a) title and full name; (b) clinic locations; (c) relevant expertise, symptoms and procedures; (d) languages spoken; (e) accepted forms of payment; and (f) education. In addition, Healthcare Providers that enter into a separate subscription agreement with us, medical insurance policies which are accepted by such Healthcare Provider and local registration and licence details;
  • Financial Data includes payment card details;
  • Transaction Data includes details about payments from you and other details of online consultations with Healthcare Provider you have booked through the Platform;
  • Technical Dataincludes 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 Platform, 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 Dataincludes your password,  and bookings made by you,;
  • Usage Dataincludes information about how you use our Platform, products and services, how you use your devices to access our Platform, including the screens you visit and searches you make; and
  • Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences..

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 Platform 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 other Special Categories of Personal Data

We do not collect any other Special Categories of Personal Data about you (this includes details about your political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Minors

By accessing, using and/or submitting information to or through the Platform and the Services, you represent that you are not a child (minor). If we learn that we have received any information directly from a child without his/her parent’s written consent, we will use that information only to respond directly to that child (or his/her parent or legal guardian) to inform the child that he/she cannot use the Services, and we will subsequently delete that information. If you are a parent or legal guardian of a minor child, you may, in compliance with the Terms of Use, use the Services on behalf of such minor child. Any information that you provide us while using the Services on behalf of your minor child will be treated as Personal Data as otherwise provided herein.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with booking services). In this case, we may have to cancel an appointment you have booked through the Platform but we will notify you if this is the case at the time.

Passwords and Confidentiality

If you are provided with a password or any other piece of information as part of our security procedures for a registration-only section of our Platform, you are responsible for maintaining the confidentiality of your password and user name for the Platform and you are responsible for all activities that are carried out under them. We do not have the means to check the identities of people using the Platform and we will not be liable where your password or user name is used by someone else. You agree to Contact us immediately of any unauthorised use of your password or user name of which you become aware. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion, you have failed to comply with any of the provisions of these terms or the Terms of Use.

  1. How is your personal data collected?

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

  • Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • fill in forms or create an account on our Platform;
    • subscribe to our service or publications;
    • request further information to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      • (A) analytics providers;
      • (B) advertising networks; and
      • (C) search information providers.
    • Contact, Financial or Transaction Data from providers of technical and payment services.
    • Healthcare Provider Data from publicly available sources and regulatory authorities.
  1. How we use your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. where we need to perform the contract we are about to enter into or have entered into with you;
  2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  3. where we need to comply with a legal obligation.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

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

We have set out in the table below a summary of the circumstances in which we will use your Personal Data, the type of Personal Data we will use and the grounds on which we will be permitted to use such Personal Data in such circumstances.

Purpose/Activity

 

Type of Personal Data

Lawful basis for processing including basis of legitimate interest

To list you as a Healthcare Provider

(a) Healthcare Provider

Necessary for our legitimate interests (to keep our records updated and to provide our services to our customers)

To register you as a user

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To process your appointment booking request

(a) Identity

(b) Contact

(c) Health Provider

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to provide service)

 

To process your appointment booking request and your online consultation request

(a) Identity

(b) Contact

(c) Health and Other Special Data

(d) Health Provider

(e) Financial

(f) Transaction

(g) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to provide service)

 

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

 

(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 Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 

To deliver relevant Platform content to you and measure or understand the effectiveness of the promotions we serve to you

 

(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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

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

(f) Marketing and Communications

 

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Deal with legal disputes and claims

(a) Identity

(b) Contact

(d) Health Provider

(e) Financial

(f) Transaction

(g) Marketing and Communications

Legitimate interests (we have a legitimate interest in being able to deal with disputes and legal claims)

Comply with a legal obligation, like a court order requiring us to release information

(a) Identity

(b) Contact

(d) Health Provider

(e) Financial

(f) Transaction

(g) Marketing and Communications

Compliance with a legal obligation

 

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us 

We may use your identity, contact, technical, usage and profile 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 purchased [goods or services] from us and 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 for marketing purposes.

Opting 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 by sending an email to help@okadoc.com.

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 experience or other transactions.

Cookies 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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.

  1. 5. Disclosures of your Personal Data

We may share your Personal Data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties being companies in our group and provide IT and system administration, poduct development, business development and back office services and undertake leadership reporting:
  • External Third Parties being:
    • in the case of Healthcare Provider Data, to our users through our Platform;
    • in the case of Identity and Contact Data, to Healthcare Providers with whom you have booked appointments through our Platform;
    • in the case of Identity, Contact, Financial Data and Transaction Data, to Healthcare Providers with whom you have booked appointments for online consultations through our Platform;
    • service providers acting as processors based in the United Arab Emirates, Saudi Arabia and Indonesia who provide IT, system administration and payment processing services.
    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in in the United Arab Emirates, Saudi Arabia and Indonesia who provide consultancy, banking, legal, insurance and accounting services.
    • Regulators and other authorities acting as processors or joint controllers based in the United Arab Emirates, Saudi Arabia and Indonesia who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. Transfers of Personal Data outside of the United Arab Emirates, Saudi Arabia and Indonesia

The Personal Data that we collect from you may be transferred to, and stored at, a destination outside of the jurisdictions in which the persons to whom such Personal Data relates being United Arab Emirates, Saudi Arabia and Indonesia. It may also be processed by staff operating outside such jurisdictions who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your booking/appointment, and the provision of support services. Your Personal Data may be transferred, stored, processed and used by our affiliated companies and/or non-affiliated service providers in one or more countries outside your originating country.

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Whenever we transfer your personal data out of such jurisdictions or to third parties, we aim ensure a similar degree of protection is afforded to it by the use of contractual obligations.

  1. Data Security

We maintain commercially reasonable technical, administrative, and physical safeguards to ensure your Personal Data is treated securely and in accordance with this Privacy Policy, and to protect against unauthorized access or alteration to, disclosure, or destruction of your Personal Data. We may, for example, use encryption technology to secure your Personal Data during transmission to our Platform as well as external firewall and on-host firewall technology to prevent network level attacks. Only those authorized employees, contractors, and agents who need to know your Personal Data in connection with the performance of their services are allowed to access this Personal Data.

It is important for you to protect yourself against unauthorised access to your password and to your devices used to access our Services. You are responsible for keeping your password confidential. For example, ensure that you sign off when you have finished using a shared device.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Platform and any transmission is at your own risk.

  1. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorised 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, regulatory, tax, accounting or other requirements.

Generally, the retention periods for different aspects of your personal data will be six years.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise 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

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. In particular, you have the right to:

  • 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.
  • 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:
    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • 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.
    • 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.

If you wish to exercise any of the rights set out above, please contact us by email at hep@okadoc.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 could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

  1. Special Note in Relation to Online Consultations

During the course of any online consultation with a practitioner which is held on our Platform, you may exchange with the practitioner through the Platform special personal data including in relation to health (health history, symptoms, examinations and tests and the results thereof, diagnosis, treatment and care plan), ethnicity, sexual orientation, sex life, religious beliefs or opinion or genetic data as relevant to the practitioner. This information is held and used by the practitioner or the healthcare provider in accordance with its privacy policy, terms and conditions of service and applicable laws and regulations. It is the responsibility of the patient to request for and consent to the privacy policy and terms and conditions of the practitioner. We do store any such information on our systems and delete such information (if shared via the Platform) from our systems after the end of any such online consultation.  

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