Quro Medical Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application means the software program provided by the Company downloaded by You on any electronic device, named Quro Medical Insight.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Quro Medical Proprietary Limited (Quro Medical), 24 Peter Place, Lyme Park, Bryanston, Johannesburg, 2060.
• Country refers to: the Republic of South Africa
• Device means any device that can access the Service such as a computer, a cell phone, or a digital tablet.
• Personal Data (also referred to as “Personal Information” in this Agreement) refers to any information that relates to an identified or identifiable individual as defined under POPIA.
• POPIA refers to the Protection of Personal Information Act 4 of 2013 and any regulations promulgated thereunder.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company (also referred to as an Operator under section 1 of POPIA). It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable i.e., the Data Subject as defined under section 1 of POPIA.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to Your:

• Email address
• First name and last name
• Phone number
• Usage Data; and
• Medical and Health Data if you are a patient.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing, and your experience.

The Company may use Personal Data for the following purposes:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to contact You.
• For business transfers:We may share or transfer Your Personal Information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share Personal Information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

If You are a patient, Your data will be stored in a secure cloud storage platform that is access controlled by the Company.

Access to Your Personal Data

As part of Our Service, the Company’s healthcare professionals will be able to visualise Your data in real time, together with Your referring physician. We understand that for purposes of providing Our Services, We will be processing Your health information, which is special Personal Information under POPIA. Only the Company and Your referring physician(s) will have access to Your data and Personal Information. It is also possible that We need to share Your data with emergency services personnel and or hospitals in the event that emergency intervention is required and or transfer to a hospital or other health establishment is required. This means We will only tell those who have a need or a right to know. Additionally, We aim to always work towards the benefit of patients and communities. In doing so, We may use Your data to work with hospitals, universities, research institutes, pharmaceutical and bio-technology companies, including organisations in other countries to develop predictive algorithms and or other useful tools which may be commercialised by the Company or used for academic research and publication, with a view to improving Our technologies, analytic capabilities, and overall public health. However, We will not share Your information with any other organisation unless it is anonymised i.e. the information cannot be traced back to You.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your continent, state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other Personal Information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data if it is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public; or
• Protect against legal liability

Security of Your Personal Data

We are obliged under POPIA to provide adequate protection for the Personal Information that we store and process to prohibit unauthorised access and use of the Personal Information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that Your Personal Information remains secure.

Our security policies and procedures cover:

• Firewalls
• Secure web gateways
• Regular vulnerability scans of IT networks and systems
• Cybersecurity awareness training for all employees
• Virus protection software and update protocols
• Logical and physical access control
• Secure setup of hardware and software making up the IT infrastructure
• Requiring Operators who Process Personal Information on behalf of Quro Medical to implement security controls in terms of Quro Medical’s contract with them

When we contract with third parties i.e., Operators we impose appropriate security, privacy, and confidentiality obligations on them to ensure that Personal Information that we remain responsible for, is kept secure. We will ensure that anyone to whom we pass your Personal Information agrees to treat your information with the same level of protection as we are obliged to under POPIA.

Children's Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your minor child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We shall take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third- party sites or services.

Your rights

We have set out Your rights in relation to Your Personal Information below. Please note that these rights do not apply in all circumstances and are subject to exceptions.

Access

You have the right to be provided with details about the Personal Information We hold about You and details of how We process it, as well as the right to receive a copy of such Personal Information.

Rectification

You have the right to obtain from Us the rectification of inaccurate Personal Information that We hold in relation to You and to have incomplete Personal Data completed, considering the purpose of the processing.

If You have an account with Us and Your Personal Information changes, We encourage You to change the Information Yourself in Your Quro Medical account profile.

Erasure

You have the right to request that Your Personal Information be erased in certain circumstances. We may continue to store Your Personal Information if We are required to retain it by law.

Restriction of processing

You can request that We restrict the processing of Your Personal Information in certain circumstances. There may be situations where We may be entitled to continue using Your information and/or to refuse your request.

Data Portability

You can ask Us to receive the Personal Information that We hold in relation to You in a structured, commonly used, and machine-readable format, to allow You to pass it to a third party, or where technically feasible to have such data transmitted directly to a third party by Us. This right applies if We are using Your data based on your consent or on a contract with You and if We are using an automated method to process it.

Objection

In certain cases, We may use Your Personal Information where it is within our legitimate interests to do so. When this is the case, You have the right to object to Us using Your Personal Information in this way. There may be situations where We are entitled to continue processing Your Personal Information and/ or to refuse your request. If we refuse to Your request, We will provide You with reasons.

Withdrawal of consent

Where We rely upon Your consent to use Your Personal Information, You have the right to withdraw consent at any time, without affecting the lawfulness of the processing based on Your consent before the withdrawal.

Automated decision-making

You have the right not to be subject to an automated decision in scenarios where the statutory requirements are not fulfilled. We do not carry out any automated decision-making processes.

Complaints

If for any reason you are not satisfied with our approach to using your personal data, please contact Our Information Officer. The details of Our Information Officer can be found in the “contact us” section below. You also have the right to complain to the data protection authority. Our data protection authority is the Information Regulator South Africa. The details of the Information Regulator are as follows:

The Information Regulator

Physical Address:

JD House

27 Stiemens Street

Braamfontein

Johannesburg

2001

Postal Address:

P.O. Box 31533

Braamfontein

Johannesburg

2017

Email: POPIAComplaints@inforegulator.org.za

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact Our information Officer at the below details:

Physical address:

24 Peter Place, Lyme Park

Sandton,

2060

Gauteng

Telephone: +27 10 824 1261 / +27 76 523 3584

Email: zikho@quromedical.co.za