PRIVACY POLICY

1. Introduction.

This Privacy Policy describes how VIRTUAL DOCTORS LIMITED collects and uses Personal Information about you through the use of our website, mobile, and through email, text, and other electronic communications between you and VIRTUAL DOCTORS LIMITED.

VIRTUAL DOCTORS LIMITED, (“VIRTUAL DOCTORS,” “we,” “our,” or “us”) respects your privacy, and we are committed to protecting it through our HIPAA compliance with this policy. This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit www. virtualdoctors. com. ng, mobile app or medical kiosk locations or any of our affiliated websites where this Policy is posted (collectively, “Website”) and the VIRTUAL DOCTORS LIMITED application (“Application”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On our Website and Application.
• In emails, text message, phone conversations, audio and video interactions and other electronic messages between you and our Website and Application.
• When you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by VIRTUAL DOCTORS LIMITED or any third party.
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or Application.

Note, VIRTUAL DOCTORS LIMITED is not a medical group. Any telehealth or telemedicine consults obtained through our website or Application, or kiosk are provided by independent medical practitioners or medical groups with a network of United States based health care providers (each, a “Provider”).

Your own medical provider if you do not use a VIRTUAL DOCTORS LIMITED Platform Medical Provider) is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not VIRTUAL DOCTORS LIMITED. If you do not agree to be bound by those terms, you are not authorized to access or use our website, and you must promptly exit our website or Application.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should elect not to use our website and Application. By accessing or using our website and/or Application, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our website or Application after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

1. Children Under the Age of 18.

Our Website and Application or Kiosk are not intended for children under the age of 18 without parental consent. If you are under the age of eighteen (18) and wish to create an account with VIRTUAL DOCTORS LIMITED, your parent or legal guardian must create the account, submit your personal information, and agree to this privacy policy on your behalf.

If you are under the age of 13, you may only use our services and access our Website and Application with the supervision and consent of your parents or legal guardians, including the Provider consultation services. If we learn that we have collected personal information from someone under the age of 13 that was not provided with the supervision and consent of the minor’s parents or legal guardian, we will promptly delete that information. If you believe we have impermissibly collected personal information from someone under the age of 13, please contact us using the information below.

1. Information We Collect About You and How We Collect It.

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally

We collect several types of information from and about users of our Website and Application (collectively, “Individual Personal Information”), specifically information:

• By which you may be personally identified, such as name, address, e-mail address, home, work, and mobile telephone numbers, date of birth, credit or debit card number (for payment purposes only), audio (including recordings and transcripts), images and videos of you, gender, Social Security Number, your medical history, health insurance subscriber information, and health information. Payment Information, Device/IP Information, Web Analytics, Geolocation Data, Other Identifying Information That You Voluntarily, Providers Services information, User Contact Data, User Demographic Data, Medical Data, Insurance Information, Booking Appointment Data, Social Network Data
• About your Internet connection, the equipment you use to access our website or use our application and usage details, such as traffic data, logs, referring/exit pages, date and time of your visit to our website or use of our application, error information, click stream data, and other communication data and the resources that you access and use on the Website or through our application.

We collect this information

• Directly from you when you provide it to us.
• Automatically as you navigate through the Website or use our application. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and from third parties, for example, our business partners.

Healthcare Provider Personal Data

Payment Information, Device/IP Information, Web Analytics, Geolocation Data, Other Identifying Information That You Voluntarily, Healthcare Provider Contact Data, Healthcare Provider Demographic Data and Professional License Information

Information You Provide to Us

The information we collect on or through our website or through our application is:

• Information that you provide by filling in forms on our website or the Application videos, images and recordings when interacting with a Provider on our Website or the Application. This includes information provided at the time of registering to use our website or Application as well as information provided when using our Provider consultation services, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our website or Application.
• Records and copies of your correspondence (including email addresses), if you contact us;
• Details of transactions you carry out through our website or through the Application and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our website or Application

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or Application or transmitted to other users of the Website or Application or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website and Application with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. The audio portion of your medical telehealth visit (including audio from visits that include video) is recorded for purposes which may include treatment, quality, improvement of health status, customer and patient experience, customer, and patient engagement and/or behavior modification, peer review, payment, efficiency, cost effectiveness and/or other purposes relating to operations and provision of telehealth services. Behavioral health visits are not recorded. By using the telehealth services available through our Website and Application you specifically consent to the recording of the medical visit.

Information We Collect through Automatic Data Collection Technologies

As you navigate through and interact with our Website and Application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

• Details of your access to and use of the Application and Website, including traffic data, location data, logs, and other communication data and the resources that the end user accesses and uses on or through the Application and Website.
• Information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Information stored on your mobile device, including in other applications. This may include, photographs, audio and video clips, personal contacts, and health information. In particular, we may collect information through your application. This data will be used only to provide and improve our services, and will not be used or shared with third parties for marketing purposes;
• Real-time information about the location of your device.

The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and Application and to deliver a better and more personalized service by enabling us to:

• Estimate our audience size and usage patterns.
• Forecast future needs, functions, and uses of our services, the Website, and the Application.
• Better understand user satisfaction levels and experiences
• Store information about your preferences, allowing us to customize our Website and our Application according to your individual interests.
• Recognize you when you return to our Website and our Application.
• In other ways to improve your experience and the quality of our Website, Application, and services.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). We and our service providers may use cookies, pixel tags, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Website and Application through your computer or mobile device or the Virtual Doctors Booth or A “cookie” is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting, you may be unable to access certain parts of our website or use certain parts of our application. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website or use our application.
• Flash Cookies. Certain features of our Website and Application may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Web site and Application. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website.
• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses cookies to help the Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www. google. com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www. google. com/analytics/learn/privacy. html.
• We use Facebook Pixel, a web analytics and advertising service provided by Facebook Inc. (“Facebook”) on our Website and Application. With its help, we can keep track of what users do after they see or click on a Facebook advertisement, keep track of users who access our Website and Application or advertisements from different devices, and better provide advertisements to our target audiences. The data from Facebook Pixel is also saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own and others advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www. facebook. com/about/privacy/. Please click here if you would like to withdraw your consent for use of your data with Facebook Pixel https://www. facebook. com/settings/?tab=ads#_=_. Please also refer to Choices About How We Use and Disclose Your Information below for more information about tracking technologies, targeted advertising and your choices relating to the use of your information for these purposes.
• Other Third Party Cookies: We encourage you to review the privacy policies of the other third party cookies deployed on our Website and Application, including Live Ramp’s (https://liveramp. com/privacy/service-privacy-policy/)and Adobe’s (https://www. adobe. com/privacy/policy. html).

1. How We Use Your Information.

We use your Personal Information for various purposes described below, including to:

• Provide our website or Application to you.
• Provide services to you.
• Provide you with information you request from us.
• Enforce our rights arising from contracts.
• Notify you about changes
• Provide you with notices about your account.

We use information that we collect about you or that you provide to us, including any Personal Information:

• To provide and improve our Website, Application, products, and services. For example, we may convert our recordings to text and perform machine learning on data we receive.
• To provide you with information, products, or services that you request from us or that may be of interest to you
• For purposes of treatment, quality, improvement of health status, customer and patient experience, customer, and patient engagement and/or behavior modification, peer review, payment, efficiency, cost effectiveness and/or other purposes relating to operations and provision of telehealth services.
• To process, fulfill, support, and administer transactions and orders for products and services ordered by you.
• To provide you with notices about your VIRTUAL DOCTORS LIMITED account.
• To contact you in response to a request.
• To administer surveys.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us or between us and health plans or other benefit programs, including for billing and collection.
• To notify you about changes to our website, our application, or any products or services we offer or provide though them.
• In any other way we may describe when you provide the information;
• For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications.

Health Information

Some information VIRTUAL DOCTORS LIMITED collects constitutes protected health information (“PHI”) under the U. S. Health Insurance Portability and Accountability Act (“HIPAA”) and Nigerian Medical and Health Law. VIRTUAL DOCTORS LIMITED will use and disclose PHI only in accordance with the healthcare providers on our application or website or organization in accordance with the medical and health data protection guidelines of our country of operation. We may de-identify your Personal Information so that it no longer reasonably identifies you. In this case, we may use this de-identified data without restriction and for any purpose, including to improve our Website, Application, and products and services.

Keeping Data Confidential

We place strict controls over our employees’ access to user data and have technical controls and audit policies in place to ensure the confidentiality, integrity, and availability of user data. Our employees and contracted personnel working with any user data are bound to our policies, and we treat these issues as matters of the highest importance.

Privacy and Security Training

Everyone at VIRTUAL DOCTORS LIMITED receives regular training to ensure that we remain focused on privacy and security. This includes privacy training that covers the Health Insurance Portability and Accountability Act (“HIPAA”) and the Nigerian Data Protection Commission (“NDPC”), which establishes national standards for protecting the identifiable health information of health plan beneficiaries and patients, and other relevant state and federal laws. We also ensure that our employees receive annual data security training, regardless of their role in the company.

Certifications and Audits

VIRTUAL DOCTORS LIMITED works with outside experts to maintain high standards and rigorous security practices. We hire third parties to test our services and processes as part of our recurring penetration testing program.

Data Encryption

We employ industry standard technology to safeguard data. Our platform uses full volume encryption on all data stored at rest, with secure backups and robust backup policies. We also use Transport Layer Security (TLS) connections to transmit data over HTTPS.

Secure Storage

VIRTUAL DOCTORS LIMITED leverages secure cloud computing, including Google Cloud platform (GCP), to store data in physically and electronically secure facilities. For a list of all current GCP security accreditations, see the GCP Compliance Programs page.

Network Protection

In addition to sophisticated system monitoring and logging, we utilize robust administrative identity, authorization, accountability, and authentication controls (including multi-factor authentication), as well as intrusion prevention and detection controls to protect our platform.

Vulnerability Management

We have a vulnerability management policy that covers internal and external testing, including annual third-party penetration testing, to find and remediate vulnerabilities that may present a risk to our platform or data.

Logging and Monitoring

VIRTUAL DOCTORS LIMITED operates an extensive security information and events management system. VIRTUAL DOCTORS LIMITED maintains a centralized logging environment, which contains events pertaining to security, monitoring, availability, access, and other metrics about the platform. We review our logging and monitoring systems regularly and respond promptly to automatic alerts.

Incident Management & Response

VIRTUAL DOCTORS LIMITED has incident management policies and procedures in place in the event of a security breach. This includes notifying users of any unauthorized access to their data in the event of a breach as defined under relevant state laws.

Product Security Practices

New features, functionality, and design changes go through a security review process facilitated by the VIRTUAL DOCTORS LIMITED development team. We utilize automated static analysis software, and our teams manually peer-review code prior to being deployed to production. The Information Security team works closely with development teams to resolve any security concerns that may arise during development.

1. Disclosure of Your Information

Payment Information, Device/IP Information, Web Analytics, Geolocation Data, Other Identifying Information That You Voluntarily, Healthcare Provider Contact Data, Healthcare Provider Demographic Data and Professional License Information

• Our affiliates and third-party service providers that we use to support our business
• To a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form.
• To comply with our legal obligations.
• To enforce our rights
• With your consent

We do not share or otherwise disclose your Personal Information for purposes other than those outlined in this Privacy Policy. We may disclose Personal Information that we collect, or you provide as described in this privacy policy. We may disclose Personal Information that we collect, or you provide as described in this privacy policy:

• To affiliates, contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, and ordering, marketing, and payment processing services.
• To a buyer or other successor in the event of 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 Information held by VIRTUAL DOCTORS LIMITED about our Website and Application users are among the assets transferred.
• To fulfill the purpose for which you provide it. For example, we may disclose your personal information to a Provider
• For any other purpose disclosed by us when you provide the information.
• With your consent, We may also disclose your Personal Information.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of VIRTUAL DOCTORS LIMITED, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

1. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted advertising. We do not control the collection and use of your information collected by third parties. We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with control over your Personal Information:

• Tracking Technologies and Advertising. You can set your browser or operating to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our website or Application may then be inaccessible or not function properly.
• Promotional Offers from VIRTUAL DOCTORS LIMITED. If you do not wish to have your email address used by VIRTUAL DOCTORS LIMITED to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any promotional emails or other marketing communications you receive from us. This opt out does not apply to information provided to VIRTUAL DOCTORS LIMITED as a result of a product purchase, or your use of our services.
• Location Information. You can choose whether or not to allow the Application to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Application may then be inaccessible or not function properly.

1. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may review and change your Personal Information by logging into the Application or Website and visiting your User Preferences page. You can review and change your Personal Information by logging into our Website or Application and visiting either the Account Details section of our Application or Website. You may also notify us through the Contact Information below of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect. With respect to any PHI in our possession, you have certain rights under HIPAA as described in the Notice of Privacy Practices provided to you by your healthcare Provider.

1. Do Not Track Signals

We currently do not use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not automatically honor such signals. However, please review other portions of this Policy regarding your ability to disable tracking technologies.

1. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Information. You can help protect your Personal Information and other information by keeping your password to our website confidential. We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use application timeouts and encryption technology for information sent and received by us. The safety and security of your information also depends on you. Where you have chosen a password for the use of our website or Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we work diligently to try and protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our website or on or through our application. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, in your operating system, or in the Application.

Google Limited Use Policy. 

Disclosure:

“Virtual Doctors Website/App’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.”

Changes to this Privacy Policy

We reserve the right to amend our Privacy Policy at our discretion and at any time. When we make changes to the Privacy Policy, we will notify you by email or through a notice on our website homepage. Use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, please do not hesitate to contact us at:

Email: [email protected]

Phone: +2347014343485