Introduction

This is the privacy policy of Doctor Care Africa relating to the processing by Us of personal data that We collect from You (or if applicable any Child), or that You or (if applicable) Your Child provide to Us, through use of a Doctor Care Africa App and/or a Doctor Care Africa Service. Unless otherwise stated, it applies to all Doctor Care Africa Apps and Doctor Care Africa Services including those provided by its Push Doctor division.

This privacy policy was last updated on the date set out above.

Under Data Protection Law We have a legal duty to protect any information We collect from You or (where appropriate Your Child) and We are committed to protecting and respecting the privacy of You and Your Child. We use leading technologies and encryption software to safeguard personal data and keep strict security standards to prevent any unauthorised access to it. Questions, comments and requests regarding our privacy policy are welcomed and should be addressed to Dr Addo at Doctor Care Africa Limited, 443 Streatham High Road, London, SW16 3PH (addo@doctorcareafrica.live) OR to our Data Protection Officer (data.protection@doctorcareafrica.live).

By using a Doctor Care Africa App or entering into a contractual relationship with Doctor Care Africa for the provision of one or more Doctor Care Africa Services to You or a member of Your family, You accept and agree to Our privacy policy and practices as described below.

Please read the following carefully to understand Our policies and practices regarding personal data and how We will treat it.

In this policy:

Child refers to any child for whom You are the parent or legal guardian or for whom You are otherwise responsible and who is entitled to use a Doctor Care Africa App (whether or not under Your supervision) in order to access a Doctor Care Africa Service or a Third Party Service
Data Protection Law refers to the DPA, the GDPR and all other laws and regulations relating to the collection and processing of personal data, whether in the UK or elsewhere
DPA DPA refers to the Data Protection Act 2018
GDPR refers to the General Data Protection Regulation (EU regulation 2016/679) as amended and in force in the UK (commonly referred to as the ‘UK GDPR’)
personal data refers to personal data as defined in the GDPR including health data or any other sensitive or special category personal data as defined in the DPA or GDPR
Doctor Care Africa refers to Doctor Care Africa Limited, and We, Us, Our, Ours and Ourselves also refer to Doctor Care Africa
Doctor Care Africa App refers to a Doctor Care Africa mobile application which is used by You to access a Doctor Care Africa Service or a Third Party Service – this includes any mobile application which has been developed in conjunction with any client or commercial partner of Doctor Care Africa (such as an insurance company or a provider of private medical services) or which is made available as part of a wider service of a client or commercial partner of Doctor Care Africa
Doctor Care Africa Client refers to a third party company or other entity which is a commercial client of Doctor Care Africa or which is otherwise in a commercial contractual relationship with Doctor Care Africa (for example, a private medical or other insurance provider, a joint venture partner or other third party which has engaged Doctor Care Africa to develop and/or provide a Doctor Care Africa App and/or a Doctor Care Africa Service, or an employer which has engaged us to provide an employee benefits service)
Doctor Care Africa Practitioner refers to a Doctor Care Africa panel doctor or healthcare practitioner, or pathology laboratory or other analysis service used by Doctor Care Africa to provide a Doctor Care Africa Service
Doctor Care Africa Service refers to a medical or healthcare service which is provided by Doctor Care Africa – whether accessed or provided via a Doctor Care Africa App or otherwise
Third Party Service refers to a service which is provided by a third party provider and which is accessed via a Doctor Care Africa App
You, Your, Yours and Yourself refer to you.

For the purpose of the DPA and GDPR, Doctor Care Africa is the data controller for personal data which are processed in connection with Doctor Care Africa Services. (It is not the data controller for personal data which are processed in connection with any Third Party Service even though the Third Party Service is accessed via a Doctor Care Africa App. It is likely that the relevant third party provider will be the data controller for that data, and You should refer to the third party provider’s privacy policy for the privacy terms which apply to that data.)

Please note that Doctor Care Africa Apps may contain links to and from applications or websites of Doctor Care Africa Clients or providers of Third Party Services. If You follow a link to any of these websites, please note that these applications or 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.

Information We may collect and process about You

We may collect and process the following personal data:

Information provided to us by You (or, where applicable, Your Child) or which We collect about You and/or Your Child (where applicable)

You or Your Child may give Us personal data (including health and medical information) by entering information through a Doctor Care Africa App, by providing information to a Doctor Care Africa Practitioner when accessing or using a Doctor Care Africa Service, by allowing Us access to personal data held by a GP or other third parties, by filling in forms, or by corresponding with Us by telephone, email or otherwise. This includes information You provide when you register to use any service of a Doctor Care Africa Client or use any element of a Doctor Care Africa Client service. We may also receive information about You or Your Child from Doctor Care Africa Clients.

You or Your Child may also give Us health and medical information and other personal data, and We may obtain and process health and medical information and other personal data about You or Your Child resulting from any interactions undertaken or services requested or sourced through a Doctor Care Africa App, including via any health or monitoring device connected to a Doctor Care Africa App, or from provision of a Doctor Care Africa Service. This includes information obtained in the course of providing consultations, tests and prescription services. Please note that consultations in the course of providing a Doctor Care Africa Service will be recorded for quality, training and monitoring purposes. Recordings may include audio, video or both and information collected includes health and medical information and other personal data contained in consultation recordings.

Information about You (or, if applicable Your Child) which is automatically collected by Doctor Care Africa Apps

Each time You (or Your Child, if applicable) use a Doctor Care Africa App We may automatically collect the following information:

technical information, including the internet protocol (IP) address used to connect the device to the internet, login information, browser type and version, and operating system and platform;
information about the visit, including the date, time and length of the visit, service elements viewed or used, response times for the Doctor Care Africa App, download errors, interaction information (such as scrolling and clicks), and any phone or other methods used to contact Us;
information from Doctor Care Africa Clients which is necessary or related to use of the Doctor Care Africa App (such as personal details and security tokens related to access by You and/or Your Child (as applicable) to a Doctor Care Africa Service or a Third Party Service), as well as from Doctor Care Africa Practitioners, providers of Third Party Services or other third parties who fulfil any service request made via the Doctor Care Africa App.

Our legal basis for collecting and processing information about You

We collect and process personal data about You (or Your Child where applicable) in order to fulfil Our contractual obligations to the Doctor Care Africa Client which provides the policy or plan under which You (and Your Child if applicable) are eligible to receive Doctor Care Africa Services.

We are required to have a legal basis for the collection and processing of this personal data, and this will be one of the following:

where it is necessary to perform a contract that we have entered into, or we will be entering into, with You;
where it is necessary for Our legitimate interests (or those of a third party such as a Doctor Care Africa Client) and Your interests or fundamental rights and freedoms do not override those interests; or
where We need to comply with a legal or regulatory obligation.

Where We use special category personal data, we are required to confirm an additional lawful basis (to that set out above) for the processing of such data, which will typically be the following:

the use is necessary for the purposes of preventive or occupational medicine, medical diagnosis or the provision of health or social care or treatment; or

• Your express consent is given.

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Cookies

A cookie is a small data file that is transferred to a computer or mobile device. We may use both session cookies and persistent cookies to better understand interactions with Doctor Care Africa Apps and/or Doctor Care Africa Services, to monitor aggregate usage by Our users and traffic routing on Doctor Care Africa Services, and to customise and improve Doctor Care Africa Services. Much of the information which We may collect through the use of cookies is non-personal data for the purposes of Data Protection Law but We treat Internet Protocol (IP) addresses and similar identifiers as personal data. Where non-personal data is combined with personal data, We also treat the combined information as personal data for the purposes of this Privacy Policy.

Uses made of information

We use information provided by You (or Your Child, if applicable) or that We collect about You or Your Child (including information that We collect from Doctor Care Africa Practitioners or other third parties as described above) in the following ways:

to provide the Doctor Care Africa Services or any other products or services requested from Us and that We agree to provide;
to review and enhance the quality of any Doctor Care Africa Service, including monitoring compliance with clinical care standards;
to make disclosures as required by Public Health England or the Office for National Statistics, or as required by or in compliance with reasonable requests by regulatory bodies such as the General Medical Council or Care Quality Commission, or as otherwise required by law or regulation;
(subject to appropriate consents), to provide information to other healthcare providers such as Your or Your Child’s GP;
to notify You about updates or other changes to a Doctor Care Africa App or a Doctor Care Africa Service and to communicate with You generally in connection with the provision of the Doctor Care Africa App or any Doctor Care Africa Service;
to assist in the detection of fraud.

We may also use information about You (and Your Child, if applicable):

to administer a Doctor Care Africa App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve a Doctor Care Africa App;
to ensure that content from a Doctor Care Africa App or any Doctor Care Africa Service is presented in the most effective manner for You (and Your Child, if applicable) and for Your device;
to allow You to participate in interactive features of a Doctor Care Africa App or any Doctor Care Africa Service when You choose to do so;
as part of our efforts to keep Doctor Care Africa Apps safe and secure;
to provide You with information about other goods and services We offer that You have enquired about;
(subject to anonymising data relating to You or Your Child, as applicable) to measure or understand the effectiveness of Our services to You and others.

Disclosure of Your information

Disclosure of information to Doctor Care Africa Clients

Where use by You or Your Child (if applicable) of a Doctor Care Africa App, or access to a Doctor Care Africa Service is linked to membership of a wider service of a Doctor Care Africa Client, We may share limited information with the relevant Doctor Care Africa Client to enable the Doctor Care Africa Client to administer its service and (where appropriate) to facilitate access to benefits under that service. However, we will only share health or medical or other sensitive information with a Doctor Care Africa Client if You have given Your consent. If we are providing medical or health-related services as part of an employee benefits service, We will not share any health or medical or other sensitive information with Your employer.

Disclosure of information to Doctor Care Africa Practitioners

We may share personal data (including health or medical information or other sensitive personal data) relating to You or Your Child (where applicable) with any Doctor Care Africa Practitioner or other medical or healthcare supplier or sub-contractor where reasonable or necessary in connection with the provision of any element of a Doctor Care Africa Service.

Disclosure of information to providers of Third Party Services

Where a Doctor Care Africa App is used by You or Your Child to access a Third Party Service We may share with the provider of that Third Party Service personal data relating to You or (where applicable Your Child) which is collected through the use by You or Your Child of the Doctor Care Africa App where reasonable or necessary in connection with access to or provision of the relevant Third Party Service. This may include health or medical information or other sensitive personal data about You or Your Child (as applicable).

Disclosure of information to affiliated companies

We may share personal data relating to You or (where applicable Your Child), including health or medical information or other sensitive personal data with any affiliated company which processes personal data on Our behalf.

Disclosure of information to other third parties

We may share personal data (but not health or medical information or other sensitive personal data) with selected third parties including:

(subject to anonymising Your personal data) advertisers and advertising networks that require the data to select and serve relevant adverts to You and others.
survey organisations, and analytics and search engine providers that assist in the improvement and optimisation of Doctor Care Africa Services and/or Doctor Care Africa Apps.
survey and other organisations that we may use to assist us in compliance with the requirements of any regulatory body such as the General Medical Council or the Care Quality Commission.

It is Your responsibility, and not Doctor Care Africa’s, to share medical and health information obtained through using a Doctor Care Africa Service with Your or (as appropriate) Your Child’s GP. We strongly encourage such sharing. We (or a Doctor Care Africa Practitioner) will only share medical information with Your or Your Child’s GP if there are significant issues which override a doctor’s duty of confidentiality to their patient and where it is consistent with the General Medical Council’s guidelines of “Good Medical Practice”.

We may disclose personal data relating to You or Your Child (if applicable) to third parties:

In the event that we sell or buy any business or assets, in which case We may disclose personal data on any anonymised basis to the prospective seller or buyer of such business or assets. But we will never disclose health or medical information or other sensitive personal data for this purpose.
If all or substantially all of Our assets are acquired by a third party as part of a sale or transfer of our business, in which case personal data held by Us about our clients and users will be one of the transferred assets.
If We are under a duty to disclose or share the personal data in order to comply with any legal obligation including the requirements of Public Health England or the Office for National Statistics, or regulatory bodies such as the General Medical Council or the Care Quality Commission, or in order to enforce or apply our terms of use of any agreement with a Doctor Care Africa Client or other third party; or to protect the rights, property, or safety of Us, Our clients and users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store and process personal data

Some personal data relating to You (and/or, if applicable, Your Child) may be held within a Doctor Care Africa App used by You. All other personal data relating to You and/or (as applicable) Your Child will be stored on secure servers located in the UK or Ireland. This includes primary and secondary care information, medication information and diagnostic information. Usually, personal data relating to You (and/or, if applicable, Your Child) will be processed only within the UK or Ireland but there may be occasions where it is processed outside the UK or Ireland, for example where a practitioner providing a consultation is located outside the UK or Ireland. Any such processing will be in full compliance with Data Protection Law.

Passwords and security

Where We have given You (or where You have chosen) a password which enables You to access a Doctor Care Africa App or a Doctor Care Africa Service, You are responsible for keeping this password confidential. We ask You not to share a password with anyone.

We encrypt data which are transmitted via Doctor Care Africa Apps. However, the transmission of information via the internet can never be completely secure due to security threats outside Our control. For this reason, although We will do our best to protect Your personal data, We cannot guarantee the security of Your data transmitted via a Doctor Care Africa App . Once We have received your information, We will use strict procedures and security features to minimise the risk of unauthorised access.

Retention of Your personal data

Personal data relating to You (or Your Child, if applicable) will normally be retained by Us for the relevant period specified below:

if You or Your Child have used a Doctor Care Africa App to obtain a Doctor Care Africa Service We will retain Your or Your Child’s personal data (so far as it is relevant to obtaining that Doctor Care Africa Service) for a maximum of 10 years in order to comply with Our contractual obligations to Doctor Care Africa Clients and/or to insurance and financial providers
if You or Your Child have downloaded or registered to use a Doctor Care Africa App but have not actually used it to obtain a Doctor Care Africa Service We will delete Your or Your Child’s personal data from Our systems after three months or, if earlier, on request by You or Your Child (as applicable) or by any relevant Doctor Care Africa Client or if Your or Your Child cease to be eligible to obtain a Doctor Care Africa Service

but We may retain information for longer periods if required by law or to comply with the requirements of Public Health England or the Office for National Statistics or they requirements or recommendations of regulatory bodies such as the General Medical Council or the Care Quality Commission.

Please see Your rights (below) for information how to request deletion of personal data.

All personal data retained by Us will be held securely as described in this privacy policy.

Your rights

You have the following rights under Data Protection Law:

To withdraw consent to the processing of Your (or, where applicable, Your Child’s) personal data – in that case We will not be able to provide Doctor Care Africa Services
To request Us to restrict the processing of Your (or, where applicable, Your Child’s) personal data – in that case We may not be able to provide Doctor Care Africa Services
To access personal data held about You (or Your Child) and to ask Us to update or correct any inaccurate personal data
To request us to delete Your (or, where applicable, Your Child’s) personal data (‘right to be forgotten’) unless We have a contractual/legal requirement to keep your data
To request Us to provide a copy of Your personal data in a ‘portable’ electronic format. Unless an alternative format is agreed, this will be provided by Us in the form of a ‘CSV’ spreadsheet.

We will not use Your personal data for marketing purposes without Your consent. If you have given Your consent, You have the right to withdraw Your consent and to ask Us not to process Your personal data for marketing purposes. If you have elected to receive marketing materials, at any time subsequently You can ask not to receive marketing materials.

You can exercise Your rights under Data Protection Law as described in this section at any time by clicking the button labelled Data Protection Rights in the side menu of the Doctor Care Africa App, OR by writing to Us at 443 Streatham High Road, London, SW16 3PH marking Your letter for the attention of the Doctor Care Africa Data Protection Officer OR by sending Your request by email to the Doctor Care Africa Data Protection Officer at data.protection@doctorcareafrica.live.

Data Protection Law also gives You the right to complain to the Supervisory Authority (www.ico.org.uk) about Our data processing activities.

Changes to our privacy policy

We may update our privacy policy from time to time. It was last updated on the date set out at the beginning of this document. Depending on the circumstances and the terms of applicable law and regulation You may be required to read and accept updated versions of this policy and/or other terms and conditions in order to continue Your use of a Doctor Care Africa App and/or a Doctor Care Africa Service.

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