Privacy Policy

PRIVACY POLICY

INTRODUCTION

Welcome to MedNet's Privacy Policy.

MedNet respects your privacy and is committed to protecting your personal data. This privacy policy applies to:

(a) The MedNet HealthPass App (‘App’) and MedNet website www.mednet.com (‘Website’), once you have downloaded or streamed a copy of the App or Website onto your mobile telephone or handheld device (‘Device’); 

(b) Any of the services that are available on the App or Website; and

(c) Any other MedNet’s services as a third party administrator as per your insurance policy terms and conditions (‘Services’).

This privacy policy sets out the basis on which any personal data MedNet collect from you, directly or indirectly, will be processed. Please read the following carefully to understand MedNet’s practices regarding your personal data and how we will treat it.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. 

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy aims to give you information on how MedNet collects and processes your personal data. It is important that you read this privacy policy to ensure you are fully aware of how and why we are using your data. 

MedNet is made up of different legal entities, details of which can be found here. When we mention "MedNet", we are referring to the relevant company in the MedNet Group responsible for processing your data which will be clear to you when you use our App, Website or Services (collectively referred to as "we", "us" or "our" in this privacy policy). MedNet UAE FZ-LLC is the controller responsible for the App and Website.

Contact details

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy or our privacy practices, please contact your MedNet customer care team, who can forward your query to the DPO. Details of the MedNet customer care teams can be found here.

You have the right to make a complaint at any time to UAE Data Office, the UAE regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the UAE Data Office so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App or log onto the Website. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or Website.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third-party links

The App and/or Website may, from time to time, contain links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins and applications and we do not accept any responsibility or liability for their privacy policies or for any personal data that may be collected through these websites, plug-ins or applications. When you leave our App or Website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data or personal information, means any information about an individual from which that person can be identified. If does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(a) Identity Data: includes first name, middle names(s), last name, maiden name, photograph, dependents, username or similar identifier, marital status, title, date of birth, gender, nationality, passport details, identity card details and residence visa details.

(b) Contact Data: includes postal address, email address and telephone numbers.

(c) Financial Data: includes bank account details.

(d) Health Data: includes information about your previous and current health claims, preexisting conditions, visits to healthcare professionals, treatments received and medications prescribed.

(e) Transaction Data: includes details about payments to you and details of claims made.

(f) Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.

(g) Content Data: includes information stored on your Device, including login information and photos, videos or other digital content.

(h) Profile Data: includes your username and password, your interests, preferences, feedback and survey responses.

(i) Usage Data: includes details of your use of any of our Apps or your visits to our Website including, but not limited to, traffic data and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.

(j) Communications Data: includes your communication preferences.

(k) Location Data: includes GPS information of your current location 

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data by law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you or your insurance provider, and if you do not provide that data when requested, we may not be able to perform the contract we have. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

(a) Information you give us or is provided by your insurance company. This is information about you (including but not limited to Identity, Contact, Health, and Financial Data), which you consent to giving us by filling in forms for your insurer or on the MN App or Website (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Website, download or register the App, subscribe to any of our Services, or submit a claim, as well as when you report a problem with the App, the website or our Services. If you contact us, we will keep a record of that correspondence.

(b) Information we collect about you and your device. Each time you visit or use one of Our Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.

(c) Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work (e.g. search nearby providers). If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings. 

(d) Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:

(i) Identity, Contact and Health data from your insurance or healthcare providers

(ii) Identity, Contact and Health data from a relative when you are a dependent of that person.

(e) Device Data from the following parties:

(i) Analytics providers (such as Google Analytics)

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

(a) where you have consented before the processing;

(b) where we need to perform a contract we are about to enter or have entered with you, or which you are a party to i.e. your insurance contract with your insurance provider;

(c) where processing is necessary for the purposes of health insurance services; or

(d) where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Cookies

A cookie is a small text file that is placed onto your Device when you use Our Sites. We use cookies to distinguish you from other users of the App and Website and to remember your preferences. This helps us to provide you with a good experience when you use the App and Website, while also allowing us to improve Our Sites. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of Our Sites may become inaccessible or not function properly

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table ‘purposes for which we will use your personal data above:

(a) MedNet Affiliated Entities 

(i) Other companies in the MedNet group who provide claims administration services.

(b) External Third Parties.

(i) The provider of your insurance policy (or their brokers) for which MedNet is the third party administrator

(ii) The healthcare provider who is administering your treatment as per your healthcare insurance policy terms and conditions (healthcare provider may or may not be within your country of residence)

(iii) The reinsurer of your insurer, on the basis of your insurer’s approval

(c) Law enforcement or other authorities if required by applicable law.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow the internal third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

Your personal data may be transferred to other companies within the MedNet Group within the region, solely for the purposes of administering your health insurance policy and processing your claims. 

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

(a) Request information about the personal data we are processing, the purposes of that processing and how we are processing your personal data. We may refuse to comply with your request if it is excessively repetitive, conflicts with judicial procedures or investigations made by any competent authorities, may adversely affect our ability to keep personal data secure or affects the privacy and confidentiality of the personal data of others.

(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(d) Object to processing of your personal data where there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to ask us not to continue to process your personal data in the circumstances set out above. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(i) if you want us to establish the data's accuracy;

(ii) where our use of the data is unlawful but you do not want us to erase it;

(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(f) Request the transfer of your personal data to you or, where technically feasible, to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 

(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise any of these rights at any time by contacting your MedNet. Details of which can be found here.  

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.