CLINICDOTS HEALTHCARE PRIVACY POLICY

Effective Date: 2/06/2025

1. Introduction

CLINICDOTS HEALTHCARE (“CLINICDOTS HEALTHCARE”, “we”, “us”, or “our”) is a digital health technology provider that enables healthcare providers and patients to access and share health information. We are not a healthcare provider and do not offer medical services or clinical advice. Instead, our role is limited to facilitating communication, data storage, and platform services between healthcare professionals and their patients.

This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you access our services through our mobile apps, web portals, APIs, and administrative dashboards.

By using our services, you agree to the practices outlined in this Privacy Policy. This Policy is designed to comply with relevant data protection laws, in accordance with applicable data protection laws and international best practices.

2. Scope

This Privacy Policy applies to all users of the Platform, including but not limited to:

• Patients receiving care or interacting with any CLINICDOTS HEALTHCARE-enabled service;
• Doctors and healthcare professionals providing services through the Platform;
• Clinic administrators, public health officials, and government stakeholders accessing or managing data;
• Any individual whose data is processed, stored, or transmitted via CLINICDOTS HEALTHCARE systems.
• All Users of the Platform, including patients, healthcare professionals, administrative staff, and government stakeholders.
• All digital interactions with CLINICDOTS HEALTHCARE, including mobile and web applications, dashboards, and integrated systems.
• All personal, identifiable, and health-related information processed through the Platform.

3. Data We Collect

3.1 Personal Identification Information

• Full name
• Email address
• Phone number
• WhatsApp number
• Date of birth and gender
• Identity documents (e.g., ID number, passport number)
• Physical address

3.2 Health and Medical Information

• Medical history, diagnoses, prescriptions, and allergies
• Consultation records, treatment notes, and referrals
• Uploaded files (e.g., X-rays, test results, lab reports)

3.3 Technical and Device Information

• IP address and device type
• Operating system and browser details
• Mobile network and geolocation data (where permitted)

3.4 Usage Data

• Interaction logs and feature usage patterns
• Appointment and teleconsultation history
• Communication and notification records

4. Legal Basis for Processing

We process your data based on one or more of the following legal grounds:

• Consent – When you voluntarily agree to data collection.
• Contractual Necessity – When processing is required to deliver services you have requested.
• Legal Obligation – To comply with health regulations or court orders.
• Legitimate Interests – To improve service quality, maintain security, or prevent fraud.
• Vital Interests – In emergencies or life-saving circumstances.

5. How We Use Your Data

Your data may also be used to enhance your experience through CLINICDOTS HEALTHCARE’s Digital Healthcare Wallet. This feature allows patients to access, manage, and share their medical history and documentation securely, giving them greater control over their healthcare journey. The wallet functionality empowers patients by providing a centralised and portable summary of their care, consultations, prescriptions, and tests, helping to facilitate continuity of care across providers, regions, or borders.

Your information may also be used in areas of the platform that offer general self-help or wellness advice. This content is provided for informational purposes only and is not tailored to individual medical conditions. It should not be interpreted as personal clinical guidance or a substitute for professional medical advice. Users must consult a qualified healthcare provider for personal diagnosis or treatment plans.

Purpose of the Self-Help Section of the App

This app provides general information to support your understanding of certain conditions and treatments, such as pregnancy journeys. It does not offer personalised advice, diagnosis, or clinical care. By using the app, you agree that it is not a substitute for formal medical intervention or care.

You acknowledge and agree that your use of the self-help section is at your own discretion and risk. You expressly waive and release CLINICDOTS HEALTHCARE, its creators, partners, and collaborators from all claims, now or in the future, for medical negligence or misinterpretation. See Clause 12 for further information. CLINICDOTS HEALTHCARE assumes no liability for any consequences resulting from reliance on generic advice within the app.

Your information may be used by healthcare providers and administrators through the CLINICDOTS HEALTHCARE platform. We act solely as a neutral technology platform and data processor on their behalf. We do not control, manage, or validate the medical decisions, clinical input, or actions taken by any user of the Platform. Your data may be used to:

• Register and verify user accounts
• Deliver clinical care and medical consultations
• Schedule appointments and generate prescriptions
• Facilitate secure communication between providers and patients
• Send health alerts, reminders, and platform notifications
• Monitor service usage and improve system functionality
• Meet legal or public health obligations

6. Data Sharing and Disclosure

We do not sell or rent your personal data. CLINICDOTS HEALTHCARE facilitates the secure exchange of data between authorised parties. Full responsibility for data entry, accuracy, compliance, and the lawful handling of personal and health data lies entirely with the healthcare provider or institution using the Platform. CLINICDOTS HEALTHCARE does not assume liability for any clinical use, decision-making, or misuse of the platform by third-party users.

We may share or transmit your data only under the following circumstances:. We may share your information only under the following circumstances:

7. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Access your personal and medical records
• Request correction of incomplete or inaccurate data
• Request erasure (right to be forgotten), subject to lawful retention obligations
• Withdraw previously given consent
• Request data portability to another provider
• Object to non-essential data processing
• Lodge complaints with a relevant data protection authority

Requests can be made by contacting: info@clinicdots.com

8. Data Storage and Retention

• Your data is stored securely in encrypted environments.
• Servers may be located in trusted, secure data centres across multiple jurisdictions with equivalent protections.
• Health records are retained for up to two (2) years, or longer if legally required or medically necessary.
• We do not retain personal or medical data longer than necessary for the purpose for which it was collected.
• Inactive accounts may be anonymised or archived in accordance with applicable legal obligations.

9. Security Measures

We apply technical and organisational safeguards to the Platform, including:

• Encryption for data at rest
• Encryption for data in transit
• Role-based access control (RBAC)
• Two-factor authentication for sensitive operations
• 24/7 infrastructure monitoring and breach response protocols

Users, including healthcare providers, are responsible for protecting their credentials and ensuring compliance with their legal and professional obligations when handling patient data. CLINICDOTS HEALTHCARE does not and cannot verify the clinical accuracy, appropriateness, or legality of any content or data entered into the system by third-party users, including healthcare professionals. and promptly report any suspicious activity.

10. Children’s Privacy

Our services are intended for adults aged 18 and over. Where services are accessed by minors, this must be done under the supervision of a parent, guardian, or legally authorised caregiver in accordance with applicable healthcare law.

11. Cookies and Tracking Technologies

CLINICDOTS HEALTHCARE uses cookies and similar technologies to:

• Maintain session integrity
• Analyse usage patterns
• Improve system functionality

You can manage cookie preferences via your browser settings. Blocking cookies may affect certain features of the Platform.

12. Third-Party and Augmented Reality Services

We may integrate with secure third-party systems (e.g. for messaging, video consultation, or cloud hosting). Each provider is independently responsible for its privacy practices. Users are encouraged to review third-party privacy policies where applicable.

Some future features of the CLINICDOTS HEALTHCARE platform may involve the use of Augmented Reality (AR) technology—for example, for anatomy visualisations, patient education, or rehabilitation support. These features will be optional and may require access to your device’s camera or sensors. We will only collect anonymised interaction data, and no identifiable video or images will be stored unless you explicitly consent. You may choose to disable AR features in your device settings at any time. We may integrate with secure third-party systems (e.g. for messaging, video consultation, or cloud hosting). Each provider is independently responsible for its privacy practices. Users are encouraged to review third-party privacy policies where applicable.

13. International Transfers and Non-Identifiable Information

CLINICDOTS HEALTHCARE may transfer your non-identifiable or encrypted data outside your country of residence to support service functionality, system hosting, or business operations. This may include transfers to locations outside your local jurisdiction, including countries that may not offer the same level of data protection.

Such transfers may also occur where you choose to seek medical advice, second opinions, or consultations with a healthcare professional located in a different country. In such cases, data will be transmitted as needed to facilitate your care.

All such transfers are performed with appropriate legal safeguards, including contractual commitments and technical security measures to ensure compliance with international data protection standards.

No matter where your data is processed or stored, CLINICDOTS HEALTHCARE ensures consistent levels of protection and confidentiality.

CLINICDOTS HEALTHCARE will never use your identifiable personal data. However, we may use aggregated or non-identifiable data for purposes such as platform improvements, public health planning, or reporting insights to ministries and policymakers, where legally appropriate.

By using our services, you consent to the international transfer of your non-identifiable personal data, in accordance with this Privacy Policy.

14. Notification of Breaches

CLINICDOTS HEALTHCARE will comply with applicable data breach notification laws in the event of a suspected or confirmed breach. While we do not store identifiable clinical data directly, all efforts are made to minimise risk. If required, affected parties and regulatory authorities will be informed promptly.

15. Updates to This Policy

This Privacy Policy is subject to change and may be updated periodically to reflect:

• Regulatory changes
• Platform or feature updates
• Security or technology advancements

Material changes will be communicated via email or platform notifications where reasonably practical. CLINICDOTS HEALTHCARE will make reasonable efforts to notify you in advance of significant updates. However, your continued use of the platform indicates acceptance of any updates.

While we take all necessary precautions to maintain transparency and integrity, CLINICDOTS HEALTHCARE accepts no liability for user misinterpretation or failure to review updated policy terms. We remain a neutral platform provider, and our responsibility is limited to communicating updates in good faith.

16. Clinical Independence and Disclaimer

CLINICDOTS HEALTHCARE is a digital health infrastructure provider and does not engage in the practice of medicine or offer any clinical services. All diagnoses, medical advice, prescriptions, treatments, or decisions are the sole responsibility of licensed healthcare professionals using the platform.

• CLINICDOTS HEALTHCARE does not review, supervise, or influence any medical judgment, nor do we verify the credentials or qualifications of healthcare providers.
• The platform operates as a neutral intermediary, and clinical liability remains solely with the healthcare professional or institution.
• Use of the platform does not create any employment, agency, or medical relationship between CLINICDOTS HEALTHCARE and healthcare professionals.

Users must seek advice from their treating doctor for all personal health issues. We disclaim all liability for health outcomes, negligence, or clinical misconduct that may arise from the use of this platform.

17. Contact Us

If you have questions, concerns, or wish to exercise your rights, please contact:

Data Protection Officer
CLINICDOTS HEALTHCARE
Email: info@clinicdots.com
Website: www.clinicdots.com