Last Updated: 01/04/19
GWI Curative Wellness Ltd. (“GWI”) is committed to respecting the privacy of every person who shares information with GWI. Your privacy is important to us and we strive to take reasonable care and protection of the information we receive from you, the User. In this regard, we adhere to the various governing laws in Nigeria and internationally, including the General Data Protection Regulations 2018 of the European Union (“GDPR”).
The terms ‘You’ or ‘Your’ refer to you as the User (registered or unregistered) of the Website and/or Services and the terms ‘We’, ‘Us” and ‘Our’ refer to GWI.
We collect Your Personal Information directly from You, from third-parties and automatically through the Our Website. This Personal Information, for instance, would relate to the type of device You are using, the time that You have logged on to Our Website, Your IP address and other Personal Information as listed in Clause 4 below.You may access the Personal Information shared by You with Us, in the manner given below. You can further choose to share additional Personal Information with Us, by writing to Us on Our below mentioned email id.We keep in mind that the Personal Information shared by You is accessible to You. You can write to Us on the below mentioned email id in Clause 15.1.
- CONTROL OVER YOUR PERSONAL INFORMATION
- You have the right to withdraw Your consent at any point, provided such withdrawal of the consent is intimated to us in writing through an email at email@example.com requesting the same. If You wish to rectify the Personal Information that we may have collected to offer You personalized services and offers, as per Clause 12 of this Policy, you may write to the Grievance Officer, as mentioned under Clause 15.1 of this Policy, citing the reason for such rectification of Personal Information.
- Once You withdraw Your Consent to share the Personal Information collected by Us, We shall have the option not to fulfill the purposes for which the said Personal Information was sought and We may restrict you from using our Services or the Website.
- PERSONAL INFORMATION COLLECTED
The kinds of information that We collect about You include but are not limited to the following:
- Patient/Caregiver/Doctor/Health Care Professional Name,
- Birth date/age,
- Address (including country and pin/postal code),
- Phone number/mobile number,
- Email address,
- Physical, physiological and mental health condition, provided by You and/or your Health Care Professional,
- Personal medical records and history,
- Valid financial information at time of purchase of product/service and/or online payment,
- Login ID and password,
- User details as provided at the time of registration or thereafter,
- Records of interaction with GWI representatives,
- Your usage details such as time, frequency, duration and pattern of use, features used and the amount of storage used,
- Master and transaction data and other data stored in Your user account,
- Internet Protocol address, cookie data, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system and other visitor details collected in Our log files,
- Any other information that is willingly shared by You (collectively referred to as “Personal Information”).
- HOW WE COLLECT PERSONAL INFORMATION
The methods by which we collect your Personal Information include but are not limited to the following:
- By filling the patient registration form,
- By providing details to a GWI Health Care Professional or GWI representative,
- When You register on Our Website,
- When You provide Your Personal Information to Us during course of receiving services,
- When You use the features on Our Website,
- When you provide access to any other website.
- USE OF PERSONAL INFORMATION
Your Personal Information may be used for various purposes including but not limited to the following:
- To provide effective Services
- To operate and improve the Website and/or our Services;
- To perform studies, research and analysis for improving Our information, analysis, services and technologies; and ensuring that the content displayed are customized to Your interests and preferences;
- To contact You via phone, SMS, WhatsApp or email for appointments, technical issues, payment reminders, deals and offers and other announcements;
- To send promotional mailings from Us or any of Our channel partners via SMS, WhatsApp, email or snail mail;
- To advertise products and services of GWI and third parties;
- To transfer information about You if we are acquired by or merged with another company;
- To share with our business partners for provision of specific services you have ordered so as to enable them to provide effective services to You;
- To administer or otherwise carry out Our obligations in relation to any agreement You have with us;
- To build your profile on the Website;
- To respond to subpoenas, court orders, or legal process, or to establish or exercise Our legal rights or defend against legal claims; and
- To aggregate Personal Information for research, statistical analysis and business intelligence purposes, and to sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates, (referred to as “Purpose(s)”)
- SHARING AND TRANSFERRING OF PERSONAL INFORMATION
- Once you have freely consented to share your Personal Information with us, You authorize us to exchange, transfer, share, part with all or any of Your Personal Information, across borders and from Your country to any other countries across the world with the Cloud Service Provider and Our affiliates / agents / third party service providers / partners / banks and financial institutions or any other persons, for the Purposes specified under this Policy or as may be required by applicable law.
- We may store temporary or permanent ‘cookies’ on your computer. You can erase or choose to block these cookies from your computer. You can configure your computer’s browser to alert you when we attempt to send you a cookie with an option to accept or refuse the cookie. If you have turned cookies off, you may be prevented from using certain features of the Website. In the course of serving advertisements or optimizing services to its Users, GWI may allow authorized third parties to place or recognize a unique cookie on the User’s browser/device. GWI does not store personally identifiable information in the cookies. Further, GWI does not exercise control over the sites displayed as search results or links from within its Services. These other sites may place their own cookies or other files on Your computer, collect data or solicit personal information from You, for which GWI is not responsible or liable. GWI encourages You to read the privacy policies of all external sites.
- The security of your Personal Information is important to us. We have adopted reasonable security practices and procedures including role-based access, password protection, encryption etc. to ensure that the Personal Information collected is secure. We restrict access to your Personal Information to Our and Our affiliates’ employees, agents, third party service providers, partners, and agencies on a need to know basis and in relation to the Purposes as specified above in this Policy.
- While We will endeavor to take all reasonable and appropriate steps to keep secure any information which We hold about You and prevent unauthorized access, You acknowledge that the internet is not 100% secure and that We cannot provide any absolute assurance regarding the security of Your Personal Information. We will not be liable in any way in relation to any breach of security or unintended loss or disclosure of information caused by Us in relation to your Personal Information.
- THIRD PARTY REFERENCES AND LINKS
- Do-not-track requests
There is no standard for how online service should respond to “Do Not Track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services. Therefore, we do not honor “Do Not Track” signals. As standards develop, we will revisit this issue and update this notice if our practices change.
- RECTIFICATION/CORRECTION OF PERSONAL INFORMATION
- If You need to update or correct your Personal Information, you may send updates and corrections to us at firstname.lastname@example.org and we will take all reasonable efforts to incorporate the changes within a reasonable period of time.
- COMPLIANCE WITH LAWS
- TERM OF STORAGE OF PERSONAL INFORMATION
- GWI shall store Your Personal Information at least for a period of three years from the last date of use of the Services or Website or for such period as may be required by law.
- GRIEVANCE OFFICER
- We have appointed a Grievance Officer to address any concerns or grievances that You may have regarding the processing of Your Personal Information. If you have any such grievances, please write to our Grievance Officer at email@example.com and Our officer will attempt to resolve Your issues in a timely manner.