GEPHA (“us”, “we”,
“APP”) is committed to protecting YOUR privacy and personal data. This
Privacy Policy is published in compliance with the law of Georgia on the
“Personal Data Protection” and explains how we collect, process, share and
protect personal data and special categories of data of our registered users
(“User”, “YOU”, “YOUR”). It also describes YOUR choices regarding use, access,
correction and deletion of YOUR personal information.
If YOU do not agree
with the data practices described in this Privacy Policy, YOU should not use
GPC or any other Services of GEPHA.
🞐 BY USING THIS APPLICATION
(APP), YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES
AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE PRIVACY
POLICY.
🞐 AFTER READING THIS
DOCUMENT, YOU HEREBY CONSENT TO COLLECTION, PROCESSING AND DISCLOSURE OF YOUR
PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY.
🞐 IF YOU USE THE APPLICATION ON BEHALF OF SOMEONE
ELSE (SUCH AS YOUR CHILD) YOU REPRESENT THAT YOU ARE AUTHORISED TO (I) ACCEPT
THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S BEHALF, AND (II) CONSENT ON BEHALF OF
SUCH INDIVIDUAL TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S
INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.
GEPHA
collects and processes personal data that is necessary to provide YOU with
services and best meet YOUR needs, for obtaining feedback in relation to the
doctors and health service or other providers, also only in aggregated or
anonymized form for statistical analysis and business intelligence purposes.
We
respect YOUR privacy and therefore, Personal data undergoing processing
is:
YOU hereby
consent to the collection and processing of such information for above
mentioned purposes by GEPHA. Information collected and processed by us from YOU
may include the following:
●
YOUR first name and last name;
●
Device that YOU use for APP;
●
YOUR residential address (Country, city and other
details of address);
●
Contact data (such as email address
and phone number);
●
Demographic data (such as YOUR
gender and date of birth);
●
YOUR ID number or number of any
other identification document, issuing country;
●
Information about a person for whom
you decided to order at-home lab tests (first name, last name, personal ID,
citizenship, date of birth, sex and e-mail).
●
Insurance data (such as YOUR
insurance company, insurance policy data, insurance plea data, letter of
guarantee, insurance plan and insurance project);
●
Information about pharmacy loyalty
or reward cards;
●
Health data – such as prescriptions,
medications, appointments with doctor, etc.;
●
First 6 or/and last 4
digits of Debit/credit card number, name and last name of card holder and
unique code of transaction;
●
Medicine purchase history acquired
via GPC;
●
Payments transactions for services /
products purchased via GPC;
●
Other information that YOU
voluntarily choose to provide to us (such as photo, height, weight, allergies,
blood group etc.).
2.1. YOU are responsible for maintaining the accuracy of the
information YOU submit to us, such as YOUR contact information provided as part
of the account registration. If YOUR personal information changes, YOU may
correct, delete inaccuracies, or amend information. We will make good faith
efforts to make requested changes in our then active databases as soon as
reasonably practicable. If YOU provide any information that is untrue,
inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date
or incomplete), or GPC has reasonable grounds to suspect that the information
provided by YOU is untrue, inaccurate, out of date or incomplete, We may
discontinue the provision of the Services to YOU according to the Georgian
legislation.
2.2. If YOU wish to deactivate or cancel YOUR account or request
that we no longer use YOUR information to provide YOU Services, contact us
through support@gpc.ge. We may retain YOUR information for as long as YOUR
account with the Services is active and as needed to provide YOU the Services.
We shall not retain such information for longer than is required for the
purposes for which the information may lawfully be used or is otherwise
required under law for the time being in force. YOUR data may be anonymized and
aggregated, and then may be held by us if necessary, for us to provide our
services effectively, but our use of anonymized data will be solely for
analytic/statistical purposes. Please note that YOUR withdrawal of consent, or
cancellation of account may result in GEPHA being unable to provide YOU with
its services or to terminate any existing relationship GEPHA may have with YOU.
2.3. If YOU wish to opt-out of receiving non-essential
communications such as promotional and marketing-related information regarding
the Services, please send us an email support@gpc.ge
2.4. If YOU pay with a debit/credit card for medical services or
healthcare products, we will collect such User’s credit card number and/or
other financial institution information such as bank account numbers and will
use that information for the billing and payment processes, including but not
limited to the use and disclosure of such credit card number and information to
third parties as necessary to complete such billing operation. Verification of
credit information, however, is accomplished solely by the User through the
authentication process. User’s credit-card/debit card details are transacted
upon secure sites of approved payment gateways which are digitally under
encryption, thereby providing the highest possible degree of care as per
current technology.
2.5. A User may have limited access to the service (e.g.
searching medications) without providing ID number and other personal data
necessary to make appointments with the doctors, receiving prescriptions, discounts
or letter of guarantees from insurance companies. In order to have access to
all the features and benefits on our APP, a User must provide ID number and
other relevant data that will be exchanged with our partner
organizations/PROVIDERS for verification.
2.6. This privacy policy applies to APP, software, products
and services owned and controlled by GPC, the owner of GEPHA (legal entity
established and operating pursuant to the Georgian legislation, with Company # 201991229). YOUR use of and access to the Services is subject to this
Privacy Policy, our terms and conditions as well as other policies. GEPHA does
not exercise control over the sites displayed as search results or links from
within its Services. These other sites may place their own cookies or other
files on the Users’ device, collect data or solicit personal information from
the Users, for which GEPHA is not responsible or liable. Accordingly, GEPHA
does not make any representations concerning the privacy practices, nor does we
guarantee the accuracy, integrity, or quality of the information, data, text,
software, sound, photographs, graphics, videos, messages
or other materials available on such websites. If YOU decide to visit a
third-party website linked, YOU do this entirely at YOUR own risk. GEPHA encourages
the User to read the privacy policies of third parties.
2.7. GEPHA implements
reasonable security practices and procedures to protect the personal data that
it has under its control from unauthorized access, improper use or disclosure,
unauthorized modification and unlawful destruction or accidental loss. However,
for any data loss or theft due to unauthorized access to the User’s electronic
devices through which the User avails the Services, GEPHA not be held liable
for any loss whatsoever incurred by the User.
2.8. GEPHA implements reasonable security practices and
procedures and has a comprehensive documented information security program and
information security policies that contain managerial, technical, operational
and physical security control measures that are commensurate with respect to
the information being collected and the nature of our business.
2.9. We take YOUR right to privacy and personal data protection
very seriously and other than as specifically stated in this Privacy Policy,
will only disclose YOUR Personal Information in the event it is required to do
so by law, supervisory body or law enforcement agency or when GEPHA, in its
sole discretion, deems it necessary in order to protect its rights or the
rights of others, to prevent harm to persons or property, to fight fraud and
credit risk, or to enforce or apply the Terms of Use.
2.10. To the extent necessary to provide Users with the Services, GEPHA
may provide Information to third party contractors who work on behalf of or
with GEPHA to maintain the APP. In such circumstances, YOU consent to us
disclosing YOUR Personal Information to contractors, solely for the intended
purposes only.
2.11. We make all User information accessible to its employees,
agents or partners and third parties only on a need-to-know basis and bind our
employees to strict confidentiality obligations.
2.12. YOU hereby agree,
that medical institutions, insurance companies and other PROVIDERS of GEPHA (referred as – PROVIDERS) that you will
choose to get service by GPC application, will process and share to GEPHA your
personal data, the processing/sharing of which is necessary in order to provide
YOU with the Services. The processing of above-mentioned data will be made
within the range and capacity, that is necessary to provide YOU with proper
Services considered by GPC .
2.13. Notwithstanding the above, GEPHA is not responsible for the
confidentiality, security or distribution of YOUR Personal Information by our
partners and third parties outside the scope of our agreement with such
partners/PROVIDERS and third parties. Further, GEPHA shall not be responsible
for any breach of security or for any actions of any third parties or events
that are beyond the reasonable control of GEPHA including but not limited to,
acts of government, computer hacking, unauthorized access to computer data and
storage device, computer crashes, breach of security and encryption, poor
quality of Internet service or telephone service of the User etc.
We may
update this Privacy Policy at any time. In the event there are significant
changes in the way we treat User’s personally identifiable information, or in
the Privacy Policy itself, we will display a notice on APP, so that YOU may
review the changed terms prior to continuing to use the Services. As always, if
YOU object to any of the changes to our terms, and YOU no longer wish to use
the Services, YOU may contact support@gpc.ge to deactivate YOUR account. Unless stated otherwise, our
current Privacy Policy applies to all information that GEPHA has about YOU and
YOUR account.
YOU
acknowledge that this Privacy Policy is a part of the Terms of Use of the APP
and the Services, and YOU unconditionally agree that becoming a User of the APP
and its Services signifies YOUR (i) assent to this Privacy Policy, and (ii)
consent to GEPHA using, collecting, processing and/or disclosing YOUR Personal
Information in the manner and for the purposes set out in this Privacy Policy
and the Terms of Use.
Should YOU have questions about this Privacy Policy or our
information collection, use and disclosure practices, YOU may contact us via
our email support@gpc.ge. We will use reasonable efforts to respond promptly to
any requests, questions or concerns, which YOU may have regarding our use of
YOUR personal information.
In certain circumstances, YOU have the following data
protection rights:
●
The right to access, update or to
delete the information we have on YOU. Whenever made possible, YOU can
access, update or request deletion of YOUR Personal Data directly within YOUR
account settings section. If YOU are unable to perform these actions yourself,
please contact us to assist YOU.
●
The right of rectification. YOU
have the right to have YOUR information rectified if that information is
inaccurate or incomplete.
●
The right to withdraw
consent. YOU also have the right to withdraw YOUR consent at any time
where GEPHA relied on YOUR consent to process YOUR personal information. In
case YOU no longer wish EKIMO to process YOUR personal information, YOU can
contact us on support@gpc.ge. Such withdrawal of the consent will trigger termination of
YOUR GPC account.
Please note that we may ask YOU to verify YOUR identity
before responding to such requests.