1) Privacy Statement
Zuri Heath Solutions Limited (Zuri Health) and its affiliates value the privacy of individuals who access our Sites and use our Services.
2) Important Definitions
“De-Identified Data”, means Data that is neither used nor intended to be used to personally identify an individual.
3) Data We Receive or Collect from You
Registration Data: When you register or create an account, you provide us with certain information, which includes your email address, telephone number, date of birth, gender, and zip or postal code (the “Registration Data”), as well as a password for your account.
Payment Information: If you choose to use a fee-based Service, you will be requested to provide (at a minimum) your name and payment information including payment card information (“Payment Information“). A third-party service provider that handles payments for us will also receive your payment card information.
Data You Choose to Provide to Us: You have the ability to provide a variety of Data during your interactions with us and the Zuri Health Services, such as emails you may send us, information you respond to, and emails or newsletters that you sign up to receive. Zuri Health or third parties acting on our behalf receive data from you whenever you provide us with Data.
Contact Data: If you choose to participate in research studies, or sign up for certain features, you may provide us, and we may collect, your contact Data, including your name, mailing address, and phone number (“Contact Data”).
Feedback and Support. We love to hear from you. Whether you have an idea to make Zuri Health better or need help, we store the emails you send us and use them to help us prioritize how to improve our product.
De-identified Data. We use de-identified data for research and development of new products or tools, to refine our algorithms and machine learning applications, and to improve the App and the services we provide. We may disclose such Data publicly and to third parties, for example, in public reports about health, to partners under agreement with us, or in benchmarking Data we provide to the medical community.
4) Data We Receive from Third Parties
Virtual Consult Summaries: At the end of every virtual visit (meaning a consultation between a doctor and a patient through our Services using text chat and/or video), the Healthcare Professional will prepare a note about the virtual visit (the “Consult Summary“), which may include health Data such as symptoms, diagnosis, and treatment. These Consult Summaries will become part of your Profile. You are solely responsible for disclosure of any personal Data to a Healthcare Professional of your choice.
Social Media Accounts: We may obtain Personal Data about you from third party social media services, such as Facebook and Twitter, if you choose to link our Services with third party social media accounts (“Social Media Account”) by either: (i) providing your Social Media Account login information to us through the Services; or (ii) allowing us to access your Social Media Account, as is permitted under the applicable terms and conditions that govern your use of the respective Social Media Account.
5) Data we collect via technology
Activity on the Sites: We may keep track of some of the actions you take on the Sites, such as the content of searches you perform on the Sites.
Access Device and Browser Data: When you access the Site from a computer or other device, we may collect anonymous Data from that device, such as your Internet protocol address, browser type, connection speed and access times (collectively, “Anonymous Data”).
Cookies: We may use both session Cookies (which expire once you close your web browser) and persistent Cookies to make the Site and Services easier to use, to make our advertising better, and to protect both you and Zuri Health. You can instruct your browser, by changing its options, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. If you do not accept Cookies, you will not be able to stay logged in to the Sites. We may also use Pixels to make the Sites and Services easier to use and to make our advertising better by, for example, summarizing usage patterns. We presently do not honor “Do Not Track” requests across all parts of our Sites.
Mobile Services: We may collect non-personal Data from your mobile device or computer. This Data is generally used to help us deliver the most relevant information to you. Examples of Data that may be collected and used include how you use the application(s) and Data about the type of device or computer you use. In addition, in the event our application(s) crashes on your mobile device we will receive Data about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s).
Zuri operates in various countries including Nigeria, Ghana, Kenya, Tanzania, Uganda, Senegal, South Africa, Zambia and Rwanda. By accessing or using the Services or otherwise providing Data to us, you consent to the processing and transfer of Data in and to the countries where Zuri Health operates.
6) How We Use Data We Receive or Collect
Generally, Zuri Health uses the Data we collect for the following purposes:
- To operate, provide, maintain, improve and enhance our Services;
- To understand and analyze how you use our Services and to develop new products, services, features, and functionality;
- To personalize your experience on our Services, such as by providing tailored content. For example, we use your email address to help you create, log into, and manage your account on our Services. This lets us personalize your experience and give you relevant information. It also powers the features that help you better understand, engage with, and track your health and to present you with personalized, relevant information;
- To enable you select a Healthcare Professional that suits your needs;
- For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you. We also may use the Data that we learn about you to assist us in advertising our Services on third party websites. Where required under applicable law, we will only send you marketing communications with your consent;
- To communicate with you via email, text messages, push notifications and phone calls, in order to provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
- To facilitate transactions and payments;
- To facilitate the connection of Social Media Accounts to our Services to provide information from Social Media Accounts to your Profile. Depending on the Social Media Accounts you choose and subject to the privacy settings that you have set in such Social Media Accounts, we will access, make available and store (if applicable and as permitted by the social media service and authorized by you) the Data in your Social Media Accounts so that it is available on and through your Profile on the Services;
- For our business purposes, such as audits, for quality assurance purposes, to find and prevent fraud, and respond to trust and safety issues that may arise;
- For other purposes for which we provide specific notice at the time the information is collected; and
- To aggregate or otherwise de-identify Data collected through the Services and use and disclose it for other business purposes after the data can no longer be reasonably linked
We may use de-identified Data without any restrictions.
Data You Share with Third Parties.
7) How we share the Personal Data we collect
Zuri Health may share or otherwise disclose Personal Data in the circumstances described below.
Affiliates: We may disclose Personal Data to our affiliates or partners to provide the Services, for the purpose of executing contracts or for other purposes for which the Data was collected.
Vendors and Service Providers: We may share Personal Data we receive with vendors and service providers in connection with the provision of the Services. In the event Personal Data is (a) to be used for a purpose that is materially different from the purposes for which the Personal Data was originally collected or subsequently authorized, or (b) transferred to a third party acting as a data controller, Members will be given, where practical and appropriate, an opportunity to opt out of having non-sensitive Personal Data used or transferred. For sensitive Data, including health related Data, members will opt in before such use or transfer.
In some instances, Zuri Health may retain other service providers to perform functions on our behalf, including, but not limited to, website developers and IT services providers.
Analytics Partners: We may make certain Personal Data available to third parties for analytics purposes, including: (a) for Zuri Health business or marketing purposes, or (b) to leverage third-party tools to understand Members’ interests, habits, and usage patterns, and/or functionality available through our Services. We only share your Personal Data with analytics partners to improve our own Services and/or to deliver healthcare to you. We do not sell your Personal Data to advertisers.
As Required by Law and Similar Disclosures: We may access, preserve, and disclose Personal Data if we believe doing so is required or appropriate, in our sole discretion, to: (a) comply with any applicable law, regulation, legal process or governmental requests, such as a court order or summons, or otherwise cooperate with law enforcement or governmental agencies; (b) take precautions against liability; (c) protect your, our, or others’ rights, property, or safety; (d) investigate and defend ourselves against any third-party claims or allegations; and (e) protect the security or integrity of our Services and any facilities or equipment used to make our Services available. For the avoidance of doubt, the disclosure of Personal Data may occur if you post any objectionable content on or through the Services.
Social Media Services: Our Services may allow you to, upon your direction, share Personal Data with certain social media services, such as Facebook, Twitter, Pinterest, and Google Plus. Please consider any impact on your privacy and anonymity when posting content to any and all social media services. You understand and agree that the use of Personal Data by any social media services will be governed by the respective privacy policies of those social media services and your settings on their platforms. We encourage you to review their privacy policies.
Marketing: We do not rent, sell, or share Personal Data about you with nonaffiliated companies for their direct marketing purposes, unless we have your permission.
Virtual Healthcare Professional Visits: We may share Personal Data with Zuri Health Healthcare Professionals in order to facilitate your treatment and care. Like an in-person patient-doctor interaction, Zuri Health virtual consults are confidential, but not anonymous. When using Zuri Health Services, your Profile information, such as your real name and health Data, are visible to the Health care Professionals with whom you see or chat within a virtual visit. This Profile information is not visible to other Members or to Healthcare Professionals who are not providing care or services in a virtual visit.
By initiating a virtual consult, you consent to sharing your name and the health Data in your Profile with Healthcare Professionals who treat you in virtual visits.
Mergers, Sales, or Other Asset Transfers: We may disclose and otherwise transfer Personal Data to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
8) Security and Data Integrity
Data Security: Zuri Health makes commercially reasonable efforts to protect Personal Data about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction by using physical and electronic safeguards designed to protect the integrity and security of the Personal Data we maintain. We take commercially reasonable precautions, considering the risks involved in the processing and the nature of the Personal Data, designed to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. However, as no electronic transmission or storage of Personal Data can be entirely secure, we can make no guarantees as to the security or privacy of Personal Data.
Data Integrity: We use the Data we collect in ways that are relevant and compatible with the purpose for which that Data was collected or provided to us as disclosed in this policy. We will take steps to ensure that all Data collected, processed, and/or stored is protected from destruction, corruption, or use in a manner inconsistent with our policies or the purpose for which we received it.
9) Our Policy Concerning Children
Zuri Health prohibits registration by and does not knowingly collect personal Data from anyone under the age of 13 years. Data relating to a child of between 14 to 18 years is only collected using an account set up and managed by an adult parent or guardian. In the event we come to the knowledge that we have collected Data from a child under the age of 13 years we will take all measures necessary to remove such Data from our servers. If you believe that we might have any personal Data from a child under 13, please contact our Feedback@zuri.health team.
10) Data Retention
11) Your Privacy Rights and Choices
- Sharing Preferences. In compliance with the law, we provide you with settings to allow you to set your sharing preferences and exercise your rights for content you post to our Services.
- Optional Profile Information: You can add, edit, or delete optional Personal Information appearing in your Profile at any time in your account settings under edit profile link.
- Required Account Information: Certain Personal Information is required for account functionality and can be edited but not deleted. For example, you can edit, but not remove, the email address and password required for login.
- Health Records: You can amend your health information and can add information to your Consult Summaries to make your information more accurate or complete. Accordingly, if you would like to request access to, or to limit the use or disclosure of Personal Data, please contact the Healthcare Professional whom you provided the Personal Data in connection with our Services. If you contact us with the name of the Healthcare Professional to whom you provided Personal Data, we will refer your request to that Healthcare Professional and support them in responding to your request.
- Public Content: You can request the removal of Public Content by contacting our support team at Support@zuri.health.
- Marketing Communications: You can unsubscribe from our marketing communications, such as announcements of new features or special offers, via the link provided in the promotional emails. Zuri Health will never share your email address or other contact Data to third parties for their own marketing purposes without your explicit permission. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
- Notifications: We will ask you if you want to receive notifications when you open an account with us. If you agree, we may send you email, SMS, or mobile push notices, providing you with account-related reminders or updates, or letting you know that you have a message on our Services. You may opt out at any time by adjusting your notification settings in the settings page.
- Do Not Track: There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
- Deactivating Your Account: you may deactivate your account at any time. To do this, sign in, go to the settings page, and choose the deactivate your account option. Your public questions that have received answers will continue to appear anonymously on our Services even if you deactivate your account.
The rights the law gives you in respect of the Personal Data we hold about you include:
- RIGHT OF ACCESS – You have the right to request a copy of the Data that we hold about you. We will respond to your access request not later than one month after receiving your request, in a structured, commonly used and machine-readable format. Zuri health subjects itself to copying the applicable regulatory authority in all such correspondence. Where we are not able to provide this personal data to you within the One-Month timeline provided by law, we will communicate same to you, and may request an additional time within which we will provide the information to you. Your Personal Data shall be provided to you in a structured, commonly used and machine-readable format.
- RIGHT TO RECTIFY – You have the right to correct the Personal Data we hold about you that is inaccurate.
- RIGHT TO BE FORGOTTEN – In certain circumstances you may ask for the data we hold about you to be erased from our record.
- RIGHT TO RESTRICT PROCESSING – Where certain conditions apply, you have a right to restrict processing of your Personal Data.
- RIGHT TO PORTABILITY – You have the right to have your Personal Data transferred to another organisation.
- LODGE COMPLAINT – You have a right to lodge a complaint about the handling of your Personal Data with the relevant regulators in the jurisdiction where Zuri Health operates.
- RIGHT TO OBJECT – You have the right to object to the Processing of Personal Data.
Please note that If you wish to exercise your rights over data protection, you may contact our Data Protection Officer at firstname.lastname@example.org or you may write to us at House 1, Emilia Apartments, Gatundu Road, Kileleshwa, Nairobi.
12) Breach/ Privacy Violation
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, Zuri Health shall report or lodge the details of the breach to the Regulator in charge of the country where such breach occurs within the lawfully prescribed timeframe.
Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within the lawfully prescribed timeframe take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.
13) Changes to this Policy
We will continue to evaluate this policy against new technologies, business practices, changes in law, and our Member needs, and may make changes to the policy accordingly. Please check this page periodically for updates. If we make any material changes to this policy, we will post the updated terms of the policy on the Services, and provide you notice of such changes, which may include notice by email through a message sent to the email address you use to access the Services.
Any material changes to this policy will be effective within thirty (30) calendar days following our dispatch of an email notice to you. These changes will be effective immediately for new users of the Services. Please note that at all times you are responsible for updating your Data to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your Data, you must notify us prior to the effective date of the changes that you wish to deactivate your account. Continued use of the Services following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
Enforcement: Zuri Health will conduct compliance audits of our relevant privacy practices to verify adherence to this policy. Further, we will conduct follow-up investigations to verify that attestations and assertions regarding our privacy practices are accurate. You may inquire about an inaccuracy or make a complaint about a potential violation to us via the contact information provided below. We do engage in training to support the implementation and compliance with our privacy practices; any employee that we determine is in violation of this policy may be subject to disciplinary action.
15) Support and Feedback
If you have any questions or would like further clarification about the Sites or Services, please contact us at Support@zuri.health. We love to hear from you. If you have an idea that can make Zuri Health better any feedback concerning our services, contact us at Feedback@zuri.health.