Privacy Notice

Introduction

Last updated on 20^th Jul 2022

Your right of Privacy is of paramount importance to us. We are committed to safeguarding your privacy and protecting your Personal Data that is with us. This Privacy Notice outlines the details of the Personal Data we collect and process, how we handle it and the purposes for which we use it. Please read the following carefully to understand our practices regarding your Personal Data.

Throughout this document, the terms “we,” “us,” “our” & “ours” refer to Health City Cayman Islands (HCCI). And the terms “you,” “your” & “yours” refer to YOU (the individual whose Personal Data we are referring to)

What Personal Data Do We Collect, Store and Process?

Categories of Personal Data that we collect, store and process are as follows:

1. Demographic, Identity & Contact Data (for e.g., name, email address, contact number, Photograph, Video).
2. Medical and Health data (for e.g., medical history, medical records).
3. Socio-Demographic Details (for e.g., Employment, Education data).
4. Authentication Data (for e.g., signatures).
5. Financial Data (for e.g., Credit Card Number, bank account details).
6. Online Identifiers and other Technical Data (for e.g., IP address, browser type, device identifiers).
7. Communications details (for e.g., communication done through emails).
8. Testimonials that may contain some Personal Data.

Where Do We Collect Your Personal Data From?

We collect your Personal Data in the following ways:

1. when you visit our facility and submit Personal details (i.e. registration forms, visitor forms, medical history) to avail of services as an in-patient, outpatient or visitor.
2. when you interact with us via our websites or mobile apps or use services on our websites or mobile apps.
3. when you interact with our staff (via Phone, fax, Third Party Applications) for customer service or to submit any documents.
4. when your images are captured by us via CCTV cameras while you are within our premises.
5. When we generate medical data based on diagnostics and observations as part of your medical treatment (e.g., Blood Reports, observations of vitals, etc.)
6. when we receive your Personal Data through third parties (e.g., medical records received through Insurance Providers or referring physicians).
7. when you submit an employment application (e.g., CV).
8. When you interact with us as part of our external programs like the Healthcare Explorer Program or the Continuous Medical Education program.

How Do We Use Your Personal Data?

We use your Personal Data for the following purposes:

If you are a Patient, we process your Personal Data for:

• Accurate diagnosis and treatment.
• Identity verification.
• Insurance, billing, customer service.
• Improving Quality of services (optimize hospital visit experience).

If you are an Employee or a potential employee, we process your Personal data for:

• Salary processing, Insurance processing, Attendance Tracking and Performance Management.
• Evaluating candidate profile against Job Openings.
• Immigration processing & other clearance related processes (Police, Medical) of international employees.

If you are a Vendor, we process your Personal data for Vendor registration and payment.

If you are a physician who is part of our Continuous Medical Education (CME) program, we process your Personal Data to

• Communicate upcoming CME events.
• Share certificates for CME events that you have attended.
• Maintain your CME credits.

• Promote the Healthcare Explorer Program.
• Maintain Waiver forms.

If you are a website visitor, we process your Personal Data to optimize your website experience and customize content.

On What Lawful Grounds Do We Process Your Personal Data?

We process your Personal Data by relying on one or more of the following lawful grounds:

1. You have consented to us processing your Personal Data for specified reasons.
2. The processing is necessary to carry out our contractual obligation with you (for e.g. To communicate with you regarding existing products and services availed by you, pay employee salaries).
3. To evaluate, develop and improve our products and services.
4. The processing is based on Vital Interests (for e.g., medical emergencies)
5. The processing is necessary for compliance with a legal obligation we may have towards other stakeholders like law enforcement agencies, government agencies, regulators, etc.

Where the processing is based on your consent, you have the right to withdraw your consent at any point in time. Upon receipt of your request to withdraw your consent, the consequences of withdrawal will be communicated to you. In many cases, upon such a withdrawal, we may not be able to continue offering our products and services to you. You may withdraw consent by contacting us using the details specified in the ‘Contact Us’ section.

Who Do We Share Your Personal Data With?

We may disclose your Personal Data to the following third parties:

• Our Parent Company for business and operational purposes
• Insurance Providers.
• Physicians or medical institutions.
• Medical Equipment Vendors.
• Government bodies (i.e., Immigration department).
• Banks.

We may also share your Personal Data under the following circumstances.

• To respond to court orders, or legal process, or to establish our legal rights or defend against legal claims.
• To investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
• If we are acquired by or merged with another company.

International Data Transfer:

We may transfer the Personal Data we hold about you to other countries outside your country of residence for any of the purposes described in this Privacy Notice. Any Personal Data that we transfer will be protected in accordance with this Privacy Notice

How Do We Secure Your Personal Data?

We are committed to protecting your Personal Data in our custody. We take reasonable steps to ensure appropriate physical, technical, and managerial safeguards are in place to protect your Personal Data from unauthorized access, alteration, transmission, and deletion. We train our employees about the importance of maintaining the privacy and security of your Personal Data. We ensure that the third parties who provide services to us under appropriate contracts take appropriate security measures to protect your Personal Data in line with our policies.

How Long Do We Keep Your Personal Data?

We retain your Personal Data for as long as it is required to fulfil the purposes outlined in this Privacy Notice by adhering to the applicable legal provisions.

How Do We Ensure Children′s Privacy?

Some of our services and processes require collection of Children′s Personal Data. For such purposes we use appropriate lawful bases for the processing. The information in the relevant parts of this notice applies to children as well as adults.

How Do We Use Cookies and other Tracking Mechanisms?

We use cookies and other tracking mechanisms on our website to collect data about you.

We use the data collected from cookies and trackers to analyze trends and statistics. This will help us optimize and customize your website experience and to provide better website functionalities.

We collect Personal Data about you via our Mobile App using permissions such as camera, storage, location, etc. Your iOS and Android devices will notify you of the permissions that our App seeks and will provide you an option to consent to or refuse the permission. We use the data obtained through permissions to enhance the functionality of the App and to analyse it to serve you better.

What Are Your Privacy Rights?

You have certain rights regarding your Personal Data that is with us, and we commit to provide you with them.

Right of Access: You have the right to get access to your Personal Data that is with us along with other supporting information.

Right to Rectification: You have the right to ask us to rectify your Personal Data that is with us that you think is inaccurate. You also have the right to ask us to complete your Personal Data that you think is incomplete.

Right to Stop or Restrict Processing: You have the right to ask us to stop or restrict the processing of your Personal Data under certain circumstances.

Right to Stop Direct Marketing: You have the right to ask us to stop the processing of your Personal Data for direct marketing purposes.

Rights in relation to automated decision making: You have the right to not be subjected to solely Automated individual decision-making, including profiling.

Right to Complain: : You have the right to lodge a complaint with the Ombudsman about any perceived Privacy violations. You can contact the Ombudsman at info@ombudsman.ky

If you wish to make a request to exercise any of your rights, you can contact us using the details in the ‘Contact us’ section of this notice.

Links to Other Websites

Our website may contain links to websites of other organisations. This privacy notice does not cover how that organisation processes Personal Data. We encourage you to read the privacy notices on the other websites you visit.

How Do We Keep This Notice Up to Date?

We regularly review and update our Privacy Notice to ensure it is up-to-date and accurate. Any changes we may make to this Privacy Notice in the future will be posted on this page. When we post changes to this Privacy Notice, we will revise the “last updated” date.

How Do You Contact Us?

For any further queries and complaints related to privacy or exercising your rights, you could reach our Data Protection Officer, Dr. Binoy Chattuparambil at: dpo@healthcity.ky