Last update: 31 January 2021
DrOnline exists to help create links between Healthcare Providers and Patients, making healthcare provision more open and inclusive. In short, to build a world where everyone can have access to Telemedicine and Video Consultancy services, anywhere. We are a community built on trust. An essential aspect of gaining that trust is to be clear about how we use your information and protect your right to privacy.
2. PERSONAL INFORMATION WE COLLECT
2.1 Information needed to use the DrOnline Platform.
We collect the following personal information when you use the DrOnline Platform. Without it, we may not be able to provide all of the services requested. This information includes Contact, Account and Profile Information. Such as your first name, last name, phone number, postal address, e-mail address, some of which will depend on the features you use. We do not collect or store any clinical information from Patients, which includes diagnoses and medical histories, prescriptions or clinical therapies.
Information you decide to provide.
You may choose to provide us with additional personal information. This information may include:
-· Additional Profile Information. As gender, preferred language(s), city and personal description. Some of this information, as indicated in your Account settings, is part of your profile page and will be visible to Health Providers with whom you conduct telemedicine consultations.
-· Other Information. For example, when you fill out a form, add information to your account, answer surveys, participate in community forums, participate in promotions, communicate with our customer support team or share your experience with us. This may include information about your health if you choose to share it with us.
2.2 Information collected automatically when using the DrOnline Platform and our Payment Services.
When you use DrOnline Platform and Payment Services, we automatically collect personal information. This information may include:
-· Geolocation Information. As the precise or approximate location determined from your IP address or GPS of your device.
-· Usage information. Like the pages or the content you view, your researches by Health Providers or Medical Services, the consultations you made and other actions in the DrOnline Platform.
-· Registration Data and Device Information. As details of how you used the DrOnline Platform (including whether you clicked on links to third-party applications), IP address, dates and times of access, hardware and software information, device information, information about events that occurred on the device, unique identifiers, crash data, cookie data, and the pages you viewed or interacted with before or after using the DrOnline Platform. We may collect this information even if you have not created a DrOnline account or logged in.
-· Payment Transaction Information. Such as the payment instrument used, the date and time, the payment amount, the expiry date and the billing zip code of the payment instrument, PayPal’s email address, IBAN data, your address and other details related to the transaction.
2.3 Personal Information We Collect From Third Parties.
We collect personal information from other sources, such as:
-· Third Party Services. If you create a link to, access or log into your DrOnline Platform Account with a third-party service (e.g. Google, Facebook, WeChat), you direct the service to send us information such as your registration information, friend list and profile in accordance with the controls on that service or authorized by you through your privacy settings on that service.
-· Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data or information to detect fraud and security issues, through third party service providers and/or partners, and combine it with the information we have about you. For example, we may receive background checks or fraud warnings from identity verification services for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the DrOnline Platform, or your experiences and interactions from our partners.
3. HOW WE USE THE INFORMATION WE COLLECT
3.1 Make Available, Improve and Optimize the DrOnline Platform.
We use personal information to:
-· allow you to access the DrOnline Platform and make and receive payments
-· to allow you to communicate with Members registered with DrOnline,
-· perform analysis, debugging and research,
-· provide customer support services,
-· send you messages, updates, security alerts and account notifications,
-· customize and adapt your experience based on your interactions with the DrOnline Platform, your search history and bookings, your profile information and preferences and other content you submit; and
-· enable you to use our company’s products.
3.2 Creating and maintaining an environment of trust and security.
We use personal information to:
-· detect and prevent cases of fraud, spam, abuse, security incidents and other malicious activities,
-· study and combat discrimination according to our Non-Discrimination Policy,
-· carry out safety investigations and risk assessments,
-· verify or authenticate the information you provide,
-· perform database checks and other sources of information, including background or police checks,
-· resolve disputes with our users,
-· to enforce our agreements with third parties,
-· comply with the law, respond to official requests, prevent harm and protect our rights,
-· Relating to the activities above, we can perform a characterization based on your interactions with the DrOnline Platform, your profile information and other content that you send to the DrOnline Platform and information obtained from third parties. In limited cases, the automated processes may restrict or suspend access to the DrOnline Platform if such processes detect activity that we think represents a security or other risk to the DrOnline Platform, to our community or to third parties. If you wish to contest the decision based on the automated process, please contact us through the Contacts section.
3.3 Make available, customize, measure and improve our Advertising and Marketing.
We use personal information to:
-· send you promotional, marketing, advertising and other information based on your preferences and social networking advertising through social networking platforms,
-· customize, measure and improve our advertising,
-· administer referral programs, prizes, questionnaires, sweepstakes, contests, or other promotional activities or events sponsored or managed by DrOnline or its partners and third parties;
-· analyze characteristics and preferences to send you promotional, marketing, advertising and other information that we think may be of interest to you; and
-· invite you to relevant events and opportunities
3.4 Providing Payment Services.
Personal information is used to allow or authorize third parties to use Payment Services:
-· Detect and prevent money laundering, fraud, abuse, security incidents.
-· Perform safety investigations and risk assessments.
-· Comply with legal obligations (such as anti-money laundering regulations).
-· With your consent, send you promotional messages, marketing, advertising and other information that may be of interest to you based on your preferences.
-· Provide and improve Payment Services.
4. SHARING AND DISSEMINATION
4.1 Share with or under your consent.
When you give your consent, we share your information as described at the time of consent.
4.2 Sharing among members.
To help facilitate scheduling telemedicine appointments or other interactions between Patients and Health Providers, we may need to share certain information, such as when a telemedicine appointment is scheduled, certain information may be shared between Patients and Health Providers, including the profile, name, cancellation history, comment information and other information you choose to share and submit. When a video consultation is confirmed, additional information is shared to help coordinate the video consultation, such as phone number and email. Whenever you have a confirmed video consultation as a Health Care Provider, we share certain information with the Patient to coordinate the appointment, such as their profile, full name, phone number, and email address.
4.3 Information you publish in profiles, advertisements and other public information.
You can make certain information public to other people, such as:
-· The Health Provider’s public profile page, which includes profile photo, name and description.
-· The Health Providers pages that include information such as the Health Provider’s description, calendar availability, your profile picture, aggregated search information (such as page views for a certain period of time), and additional information you decide to share.
-· Comments, ratings and other public comments.
-· Content in a community or discussion forum, blog or social network publication.
We may display parts of your public profile and other Content that you make available to the public, such as Health Provider Details on third-party websites, platforms and applications.
The information you share publicly on the DrOnline Platform can be indexed through third-party search engines.
4.4 Comply with the Law, respond to official requests and protect our rights.
We may disclose your information to courts, law enforcement, government or public authorities, tax authorities or authorized third parties if and to the extent we are required or permitted by law or when disclosure is reasonably necessary: (i) to comply with our legal obligations; (ii) to comply with a valid legal request or to respond to actions brought against DrOnline; (iii) to respond to a valid legal request related to a criminal investigation, or alleged or suspected illegal activity, or any other activity that could expose DrOnline, expose you or any of our users to legal liability; (iv) to implement and administer our Terms of Service or others arrangements concluded with Members; or (v) to protect the rights, property or personal safety of DrOnline, its employees, Members or members of the public. For example, if permitted under the terms above, the Health Care Provider’s tax information may be shared with tax authorities or other government agencies.
Where appropriate, we may notify Members of official requests, unless otherwise notified: (i) the legal regime itself, the court order received, or the law in effect prohibits notification; or (ii) we believe that sending a notification would be futile, ineffective, could carry a risk of negative effects or bodily harm to a person or group, or would carry or increase the risk of fraud or harm being committed against DrOnline, its Members, or would expose DrOnline to obstruction of justice.
In jurisdictions where DrOnline facilitates Tax Collection and Referral, where legally permitted under applicable law, we may disclose information from Patients and Health Care Providers about transactions, appointments, to the appropriate tax authorities, including, but not limited to, the name of the Patient or Health Care Provider, dates and amounts of the transactions, tax identification number(s), the amount of taxes received (or owed) by the Health Care Provider, the Patient, and contact information.
In jurisdictions where DrOnline facilitates or requires a registration, notification, license or license application from a Health Care Provider with a local government authority through DrOnline in accordance with local law, we may share information from participating Health Care Providers with the relevant authority both during the application process and periodically thereafter, as well as the Health Care Provider’s full name and contact details and tax identification number.
4.5 Service Providers.
We share personal information with affiliated and non-affiliated service providers to help us run our business, including service providers who help us to: (i) verify your identity or authenticate your identification documents; (ii) verify information from public databases; (iii) conduct background and police checks, fraud prevention and risk assessments; (iv) perform product development, maintenance and debugging; (v) enable the provision of DrOnline Services through third-party software platforms and tools (for example, through integration with our APIs); (vi) provide customer services, advertising or payment services; (vii) process, evaluate or address insurance or other similar claims; or (viii) facilitate non-profit and solidarity activities consistent with DrOnline’s mission. These providers are contractually obligated to protect your personal information and have access to your personal information to perform these tasks.
4.6 Business Transfers.
5. OTHER IMPORTANT INFORMATION
5.1 Analysis of your Communications.
We may review, scan or analyze your communications on the DrOnline Platform for the reasons described in the “How We Use the Information We Collect” section of this policy, including for fraud prevention, risk assessment, regulatory compliance, research, product development, research, analysis, application of our Terms of Serviceand for customer service purposes. For example, as part of our efforts to prevent fraud, we may scan and analyze messages to hide contact information and references to other websites. In some cases, we may also scan, review or analyse messages to debug, improve and extend product offerings. We use automated methods where reasonably possible. There will be times when we may need to manually review communications, such as in fraud investigations and customer support, or to evaluate and optimize the operation of these automated tools. We will not review, scan or analyze your instant messaging communications for the purpose of sending you marketing messages from third parties, and we will not sell reviews or analyses of these communications.
5.2 Association to Third Party Accounts.
You can link your DrOnline Account to certain third-party services, such as social networking. Your contacts in these third party services are referred to as “Friends”. By directing data sharing through the creation of this link:
-· Some of the information provided to us through the association of your accounts may be published in your public profile,
-· your activities in the DrOnline Platform can be presented to your Friends in the DrOnline Platform and/or the service of the third party in question;
-· a link to your public profile on DrOnline may be included in your public profile on the third party service;
-· other users of DrOnline may eventually see Friends who have in common, or who are a Friend of the user in question, as appropriate;
-· Other users of DrOnline may eventually see the schools, naturalities or other groups that have in common and that are indicated in the social network to which it is associated;
-· the information you provide to us through the association of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
-· The publication and presentation of information that you provide to the DrOnline Platform through this association is subject to their definitions and authorizations in the DrOnline Platform and the third party service.
5.3 Third Party Partners and Integrations.
Some parts of DrOnline may be linked to third-party services not owned or controlled by DrOnline. Use of these services is subject to the respective privacy policies of those providers. DrOnline does not own or control these third parties and when you interact with them you are providing their information to them.
6. YOUR RIGHTS
You may exercise any of the rights described in this section in accordance with the applicable law.
6.1 Managing your information.
You can access and update some of your personal information through your Account settings. If you have linked your DrOnline Account to a third-party service, such as Facebook or Google, you can change your settings and dissociate that service from your Account settings. You are responsible for keeping your personal information up-to-date.
6.2 Data Access and Portability.
You may request certain copies of your personal information or information about how we handle your personal information, request copies of the personal information you have provided to us in a structured, usually used and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).
6.3 Deletion of data.
You can request that your personal information be deleted. Please note that if you request the deletion of your personal information:
-· We may retain and use your personal information to the extent necessary to fulfill our legal obligations. For example, DrOnline may retain your information for tax obligations, legal reporting and auditing.
-· The information you have shared with others (for example, comments and evaluations) will continue to be publicly visible in DrOnline, even after your DrOnline Account is cancelled. However, access and communication to you of such information will be removed. Some copies of your information (e.g., protocol logs) will remain in our database, but are separated from your personal identifiers.
-· Because we take steps to protect data from accidental or malicious loss or destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
While no organization can guarantee perfect security, we are constantly implementing and updating administrative, technical and physical security measures to help us protect your information from unauthorized access, loss, destruction or alteration.