Last updated: October 2024

1. Aim and purpose of this Privacy Policy 
   
   1. PHMS is committed to maintaining your trust by ensuring that your privacy is protected. This Privacy Policy explains how we collect, use, share and protect personal data when you register or use our App, including our Online Doctor Service. For the purposes of this Privacy Policy, PHMS is the ‘Data Controller’ who determines the purposes for processing your personal data.
   2. We process your personal data in a transparent and lawful way. Any personal data you provide will only be used in accordance with this Privacy Policy.
   3. This Privacy Policy applies only to the App and the Services when you interact with us and does not apply to services that are “offline” or unrelated to the App. We may create de-identified or anonymous data from personal data by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you, through obfuscation, or through other means. Our use of anonymized and de-identified data is not subject to this Privacy Policy.
   4. All terms used are defined in our Terms of Use, unless otherwise stated.

 

2. Definitions
   
   2. Personal data means any data related to a specific natural person, or related to a natural person who can be identified directly or indirectly by linking the data, through the use of identifying elements such as his name, voice, identification number, electronic ID, or geographic location, or one or more of its formal, physiological, economic, cultural, or social characteristics, including sensitive personal data and biometric data.
   3. Sensitive personal data means any data that reveals, directly or indirectly, a natural person’s family, ethnic origin, political or philosophical opinions, religious beliefs, criminal record, biometric data, or any data related to that person’s health. It includes his physical, psychological, mental, mental, physical, genetic, or sexual condition, including information related to the provision of health care services to him that reveals his health status.
   4. Biometric data means personal data resulting from processing using a specific technology relating to the physical, physiological or behavioral characteristics of the data subject, which allows the identification or confirmation of the unique identification of the data subject, such as a facial image or fingerprint data.
3. Your Consent
   
   3. If you choose not to register or provide your personal data, you may not be able to use our App and the Services. 
   4. You agree to receive our routine communications to you such as emails, and other administrative messages through email and notifications posted on the App or through other means available, including text and phone calls, related to your profile on the App. 
   5.  You must ensure to provide us with the correct or updated personal data. This will allow us to contact you for further correspondences. We are not responsible for any inaccurate information you provide to us.
   6. If, at any time, you want to access, update, modify or eliminate any of your account information on the App, you may do so by clicking “Profile”, and then review/change your personal data as you want it to be.
   7. We may, in future, request other optional information from you to customize the App to deliver personalized Services to you.
   8. We do not make unauthorized calls or market any goods or services except for the reasons mentioned in the Terms of Use. Therefore, you shall not reveal personal data to any third party not approved by us. 

 

4. Personal Data Collection Methods and Categories
   
   4.  “Personal Information” is collected when you use or interact with our Services, this includes when you register on the App or otherwise use the Services (e.g., browse the content available on the App), and when you ask us to customize our Services. This personal data may include name, photo, password, email address, phone number, date of birth, gender, nationality, general identification data, payment details that shall be processed and stored by PayTabs.
   5. “Fitness and Wellness Data” is also collected, this includes data you provide related to your dietary habits, dietary restrictions, fitness activity, fitness goals, lifestyle (e.g., sleeping habits), life events, fitness goals, height, weight, measurements, fitness level, heart rate, sleep data, BMI, biometric data, and similar types of data relating to physiological condition, and activity. We collect this data in order to provide the Services and to tailor features and Services to your interests and goals, including providing reporting and analytics, workout plans, and product recommendations.
   6. “Health Data” includes data you provide when booking an online consultation through our Online Doctor Service, such as the responses to the online consultations you chose to give and any follow ups. This data includes (but is not limited to) gender, sexual history, medical and medication history or consultation notes. We collect this data to provide the Online Doctor Service to you and any additional features or related Services, to improve our Online Doctor Service and for statistical and research purposes. 
   7. “Usage Information” includes technical information such as IP addresses, web browser type and version, browser plugin type and version, time zone, platform and operating system. We collect this data when you interact with our app to improve our App’s functionality, user experience and effectiveness.

 

4. If you want to use any of the Services provided on the App, you agree to provide us with your personal data mentioned above. PHMS and PHMS representatives may request such personal data and other information that may be required from time to time, via email, telephone, or texts. 

 

4. As stated above, if you do not consent to the processing of your Personal Data described above, you may still be able to use the App, but certain features and services may be limited which depend on the use of such Personal Data (for example Online Doctor Service, Diabetes Care or Features which depend on the use of location data).

 

5. Utilization of Your Personal Data
   
   5. We may require any or all of the personal and sensitive personal data mentioned above, either directly or through our Service Providers, to deliver the best possible Services and enhance your experience when using the App. 
   6. Under the applicable health and data protection laws, we only process your personal data for the following reasons:
      
      5. where you have given your consent;
      6. to comply with our legal and regulatory obligations; or
      7. for the performance of a contract with you or to take steps at your request before entering into a contract.
      8. to manage your Subscription package as chosen by you.
   7. When processing sensitive personal data, we ensure compliance with additional requirements:
      
      5. where we have your explicit consent;
      6. where the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
      7. where the processing is necessary to establish, exercise or defend against legal claims.
6.       Sharing your personal data
   
   6. We regularly share personal data with:
      
      6. Our Service Providers; and
      7. Other third parties assisting in the App’s operations (e.g., marketing agencies, website hosts, payment channels etc..).[TA1] [DSM2] [TA3] 

 

 

6. We permit these organizations to handle your personal data only after ensuring their adherence to appropriate protective measures. Additionally, we impose contractual obligations on them, stipulating the exclusive use of your personal data for providing Services to us and to you.
7. We may disclose certain information, including your personal data, to legal and professional advisers when necessary to fulfill a legal requirement or respond to law enforcement agency requests.

Marketing

6. We prioritize your privacy and respect your preferences for marketing communications. We will use your personal data to send you updates (through the App, by email, text message, telephone or by post) about our Services, including exclusive offers, promotions, Subscriptions plans, or new products. Your explicit consent is required for marketing purposes.
7. You do, however, have the right to opt out of receiving marketing communications at any time by:
   
   6. contacting us at [email protected]; or
   7. using the ‘unsubscribe’ link in emails. 

 

7. Transferring your personal data
   
   7. Personal data may be held at our offices and with our Service Providers or third parties. Some of these Service Providers and third parties may be based outside the United Arab Emirates (UAE). Where it is permissible under the applicable health and data protection laws, we may share and/or transfer your personal data outside the UAE.
      
      7. Certain countries are considered safe by regulators since they have adequate data protection laws. We can freely transfer your personal information where needed.
      8. We can also transfer personal information to countries that have not been assessed as adequate if we use appropriate safeguards. The main safeguards we use are:
         
         7. regulator-approved Standard Contractual Clauses; and /or 
         8. additional contractual, organizational, and technical measures (as required following a risk assessment of the transfer). 
   8. We transfer personal data within the Group (i.e. entities affiliated to and/or controlled by PHMS or its parent entity). Such transfers are covered by an agreement that contractually obliges each company to ensure an adequate and consistent level of protection.
   9. In all of the above cases we will comply with applicable health and data protection laws designed to ensure the privacy of your personal data.

 

8. Your rights
   
   8. You have the following rights, which you can exercise free of charge:

Withdraw Consent	You have the right to withdraw your consent for Services such as marketing communication. Simply contact us, and we’ll manage your preferences accordingly. If you have provided us with a consent to use your personal data, you have a right to withdraw that consent easily at any time. You may withdraw consent by emailing us on [email protected] Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.
Access Your Data	Please reach out to us if you wish to know what data we have stored about you.
Correct or Delete Your Data	Please keep us updated if your personal data requires correction or deletion.  If you want certain stored data deleted, contact us. While we strive to honour such requests, certain legal obligations may apply.
Limit Data Processing	If you prefer not to delete certain information but limit its use, please reach out and we will amend your preferences accordingly.
Data portability	Where you require us to transfer your personal data to a Service Provider or third party (in certain situations as permissible under the applicable health and data protection laws), please let us know as we can provide it in a zipped format for your convenience.
Object to Handling	The right to object: —at any time to your personal data being processed for direct marketing (including profiling) —in certain other situations to our continued processing of your personal data, e.g. the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Complaints:	If you have concerns, you have the right to lodge complaints with the supervisory authority or our Data Protection Officer. Feel free to contact them directly.

9. Personal Data Security
   
   9. We implement appropriate industry standard security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction and prevent personal data from being lost accidentally or used or accessed unlawfully. These measures shall consider the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in accordance with the applicable health and data protection laws.
   10. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorized manner and are subject to a duty of confidentiality.
   11. Your data is stored securely on servers with restricted access, and we use encryption protocols to safeguard sensitive personal data. We employ various types of technical and physical access controls, which may include, if appropriate, encryption. We may also aggregate, pseudonymize or anonymize personal data to ensure that no personally identifiable personal data is shared with a third party, unless we have your consent, or it complies with one of the purposes listed under section5.
   12. We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
10. Personal Data Storage and Retention
    
    10. . We will only retain your personal data for the duration necessary to fulfill its intended purpose.
11. Changes to this Privacy Policy
    
    11. We may change this Privacy Policy from time to time. Where there are material changes or where the purposes of processing your personal data have changed, we will inform you and/or reach out to you via email and/or by way of notice on the App.
12.  Contacting Us
    
    12. If you have any questions or concerns regarding this Privacy Policy or our data practices, please contact us at: care.pura@pura.ai

 

 [TA1]Project team to confirm if PayTabs will receive any such info so that we add its name in this section.

 [TA3]Added PayTabs.