SandsClinic

PRIVACY POLICY

This privacy policy applies to the information that we collect from you when you use our website(s), www.sandsclinic.com, and our mobile application collectively and hereinafter called “Platform.”

Our privacy policy explains what personal data and non personal data we may collect from you, how we collect them, how we protect them and how we use them. It also explains how you can access and change them. Our privacy notice also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our Platform.

Definitions ‘NON PERSONAL DATA’ (NPD) is information that is in no way personally identifiable.

‘PERSONAL DATA’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified directly or indirectly by reference to an identifier such as a name, an identification number, location data, or an online identifier.

Our legal basis for collecting and processing your PD when you sign up for our services is based on and the necessity for the performance of a contract or to take steps to enter into a contract. Our legal basis for collecting and processing your PD when you sign up for our newsletter, medical articles, instructional videos on nutrition and exercise is based on consent.

Data obtained from Consultations will be anonymized and de-identified before being analyzed and used by SandsClinic for product development and research purposes.

We will use the personal information that we collect from you to schedule, administer and personalize your Consultations, update your patient record and to provide you with healthcare services.

We may disclose your personal information, to third-party healthcare professionals involved in providing you with healthcare services, such as a specialist physician, pharmacist, physiotherapist, psychologist, counsellor, nutritionist, clinical researcher or lab technician. When the disclosure is part of a care plan that you have agreed to, we will consider the agreed care plan to constitute implied consent. For all other disclosures to a third-party not associated with SandsClinic, we will only make the disclosure after obtaining your express consent.

Only healthcare professionals and their delegates involved in providing you with healthcare services can access your personal information. All delegates who are not regulated healthcare professionals sign strict and durable confidentiality agreements.

Access to your information is logged and we perform regular audits in order to ensure that any access is authorized and that information is only accessed on a ‘need to know’ basis. We may share with selected third-parties demographic and contact information about you (including but not limited to name, date of birth and any email addresses or phone numbers) by email, SMS, instant messaging or any other means necessary, for reasons including but not limited to: verifying your identity, medical follow-up, scheduling appointments, confirming appointments, customer support and technical support.

HOW YOUR INFORMATION IS USED AND SHARED

We use the information we receive from you to: provide our products and services you have requested or purchased from us personalize and customize our content make improvements to our Platform contact you with updates to our Platform, products, and services resolve problems and disputes provide health care services and information to you

Communications and Emails When we communicate with you, we will use the email address you provided when you registered as a user or customer. We may also send you emails with promotional information about our Platform or offers from us or our affiliates unless you have opted out of receiving such information. You can change your contact preferences at any time through your account or by contacting us using the contact information at the top of this privacy notice.

Sharing Information with Affiliates and Other Third Parties

We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your NPD, which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. We may give your PD to third-party service providers whom we hire or contract to provide services to us.

These third-party service providers may include but are not limited to payment processors, web analytics companies, physicians, medical assistants, medical services, medical research companies, call centers, data management services, help desk providers, accountants, law firms, insurance companies, shopping cart and email service providers, and shipping companies.

Text Messaging and Push Notifications

If you provide a mobile telephone number to us, you are giving your consent and authorize us or a third party to send you text messages and push notifications. You are not required to give us your consent for these text messages and push notifications. However, withholding your consent may interfere or prevent us from providing some or all of our services to you. You can stop receiving text messages and push notifications at any time by contacting us.

Legally Required Releases of Information

We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or governmental enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our terms and conditions; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.

Disclosures to Successors

If our business is sold or merges in whole or in part with another business that would become responsible for providing our Platform to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.

RETAINING AND DESTROYING YOUR PERSONAL DATA

We retain information that we collect from you (including your PD) only for as long as we need it for clinical, legal, medico-legal, business, or tax purposes. Your information may be retained in electronic, paper, or a combination of both forms. When your information is no longer needed, we will destroy, delete, or erase it.

UPDATING YOUR PERSONAL DATA

You can update your PD using services found on our Platform. If no such services exist, you can contact us using the contact information found at the top of this privacy notice and we will help you. However, we may keep your PD as needed to enforce our agreements and to comply with any legal obligations.

REVOKING YOUR CONSENT FOR USING YOUR PERSONAL DATA

You have the right to revoke your consent for us to use your PD at any time. If you opt out, it will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to affiliates and business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or third-party offers you may choose to accept. If you want to revoke your consent for us to use your PD, please contact us through the contact information at the top of this privacy notice.

PASSWORDS

Users can also be assigned an SandsClinic ID number, and may then may be asked to change their password.

When you register as a user, member, or when buying our products or services, we may collect some or all of the following information: your first and last name, date of birth, gender, email address, physical address, phone number, insurance information, IP address, user name, password, health information and next of kin’s contact information (name, phone number, and email address).

WEBSITE CHAT AND VIDEO CONSULTATION

Our Platform contains chat and video consultation technology that enable visitors to communicate with us live online. When you use our chat or video consultation technology, we may collect some or all of the following information: your email address, first name, last name, location, date of birth, phone number, health information, and any other information you willingly choose to give us. You should only provide enough information to us that is necessary to answer our questions.

WEB BEACONS

We may also use a technology called web beacons to collect general information about your use of our Platform and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers and users.

GOOGLE ANALYTICS

Our Platform uses Google Analytics to collect information about the use of our Platform. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our Platform, what pages they visit, and what other websites they have used before coming to our Platform. We use the information we get from Google Analytics to analyze traffic, improve our marketing, advertising, and Platform.

Google Analytics collects only the IP address assigned to you on the date you visit our Platform, not your name or other identifying information. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you use our Platform, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our Platform.

For more information on how Google collects and processes your data visit: HTTPS://WWW.GOOGLE.COM/POLICIES/PRIVACY/PARTNERS/You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout

If you do not provide us with enough personal information, we may not be able to provide you all our services optimally. However, you can access and use some parts of our Platform without giving us your Personal details.

COOKIES

Our Platform uses cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well.

By agreeing to use our service you accept our use of cookies and you are giving us and the third parties with which we partner permission to place, store, and access some or all the cookies described below on your computer.

Strictly Necessary Cookies - These cookies are necessary for proper functioning of the Platform, such as displaying content, logging in, validating your session, responding to your request for services, and other functions. Most web browsers can be set to disable the use of cookies. If you disable these cookies, you may not be able to access features on our Platform correctly or at all.

Performance Cookies - These cookies collect information about the use of the Platform, such as pages visited, traffic sources, users’ interests, content management, and other measurements.

Functional Cookies - These cookies enable the Platform to remember users’ choices, such as their language, usernames, and other choices while using the Platform. They can also be used to deliver services, such as letting a user create a blog post, listen to audios, or watch videos on the

Platform. Media Cookies - These cookies can be used to improve a Platforms performance and provide special features and content. They can be placed by us or third parties who provide services to us.

Advertising or Targeting Cookies - These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.

Session Cookies - These cookies allow a Platform to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they browse a Platform. Session cookies also permit users to be recognized as they navigate a Platform so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; they are not stored long term.

Persistent Cookies - These cookies are stored on a user’s device between browser sessions, which allows the user’s preferences or actions across a website or across different websites to be remembered. Persistent cookies may be used for several purposes, including remembering users’ choices and preferences when using a Platform or to target advertising to them.We may also use cookies for: identifying the areas of our Platform that you have visited personalizing content that you see on our Platform our Platform analytics remembering your preferences, settings, and login details allowing you to post comments

Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access features on our Platform correctly or at all.

PROTECTING CHILDREN’S PRIVACY

Our Platform is not designed for use by anyone under the age of 16 unless the age of consent in their country provides for 13, 14 and 15-year old children to give us their consent to collect personal data from them. In countries where the age of consent is 16 or older, the child will need parental consent before providing us with their personal data. In all cases, we do not knowingly collect PD from children under the age of 13 without parental consent.

If you are a parent or guardian and believe that your child is using our Platform without your required consent, please contact us. Before we remove any information we may ask for proof of identification to prevent malicious removal of account information. If we discover that an unauthorized child is using our Platform, we will delete his or her information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor have any liability to do so.

THIRD PARTIES

If any postings you make on our Platform contain information about third parties, you agree to make sure that you have permission to include that information. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified, if such postings violate the privacy rights of others. .

LINKS TO OTHER WEBSITES

Our Platform may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. These websites will likely have their own privacy notices. We have no responsibility for these websites and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy notices of these websites to see how they treat your PD.

OUR SECURITY POLICY

We have built our Platform using industry-standard security measures and authentication tools to protect the security of your PD. We and the third parties who provide services to us also maintain technical and physical safeguards to protect your PD. Unfortunately we cannot guarantee prevention of loss or misuse of your PD or secure data transmission over the Internet because of its nature. We strongly urge you to protect any password you may have for our Platform and not share it with anyone.

Safeguarding your Information All communication is encrypted end-to-end, including video and all interactions with you. SandsClinic has implemented written policies and procedures that address the privacy and security of your Personal Information. Sandsclinic delivers privacy training to employees and contractors to ensure personal information is safeguarded and to mitigate operational risks. All employees and contractors are legally bound to confidentiality.

SandsClinic is committed to protecting and securing your data. However, there is no guarantee against data and security breaches. However, we have taken reasonable measures to prevent breaches. In the event of any such data breach, SandsClinic will notify users at the first reasonable opportunity of the circumstances surrounding the breach, and immediately apply available urgent counter measures.

USE OF CREDIT AND DEBIT CARDS

You may have to use your credit card or debit card to pay for a subscription plan on our Platform. We use third-party billing services and have no control over them. We use commercially reasonable efforts to ensure that your credit/debit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorized use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number. Payments are processed via a third party payment provider that is fully compliant with Level 1 Payment Card Industry (PCI) data security standards. Sandsclinic does not store any credit card information within our systems.

OUR EMAIL POLICY

You can always opt out of receiving email correspondence from us or our affiliates. We will not sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business, or if our company files for bankruptcy.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this privacy notice at any time. If our company decides to change this privacy notice, we will post those changes on our Platform so that our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email sent to the email address on file in your account. Otherwise we will use and disclose our users’ and customers’ PD in agreement with the privacy notice in effect when the information was collected. In all cases your continued use of our Platform, services, and products after any change to this privacy notice will constitute your acceptance of such change. If you have questions about our privacy notice, please contact us through the information at the top of this privacy notice.