Privacy policy 

Date of Last Revision: 12 November 2024

 NAWAT Health Technologies LTD (“NAWAT”, “We”, “Us”, or “Our”) is committed to protecting the privacy and security of personal information. This privacy policy (“Privacy Policy”) describes how We collect and use personal information about users (“You”, or “Your”) when You visit the NAWAT platform (the “Platform”).

Please read this Privacy Policy carefully and if You have any questions about this Privacy Policy, please contact Us using the contact details provided below.

Our Platform Terms and Conditions (the “Terms”) explain the terms on which You are allowed to use the Platform. Please click here to access the Terms. All defined terms used in this Privacy Policy shall have the same meaning ascribed to them in Our Terms unless expressly otherwise provided for.

We may also change this Privacy Policy from time to time without prior notice by updating this page. It is Your responsibility to check Our Privacy Policy periodically to ensure that You are happy with any changes. Any changes will be effective immediately upon publication on the Platform. Your continued use of the Platform following any changes to this Privacy Policy will mean that You accept such changes.

1.    Type of Personal Data We Collect

 For the purposes of this Privacy Policy, “Personal Data” is any information which relates to You. This includes (but is not limited to) Your name, address, birth date, email address, telephone number, health related information (such as information relating to Your physical or mental health condition and the treatment and provision of healthcare services to You), or other information which may be used to directly or indirectly identifying You, such as cookies credentials, security information, and feedback. Personal Data does not include information that cannot be linked to You, such as aggregated and anonymized data from which names or other identifiers have been irretrievably removed.

The Personal Data We collect and process about You will, to some extent, be determined by Your use of the Platform. However, in all cases, We ask for the following Personal Data when You register to use the Platform:

·       name (although legal names are only used where necessary for medical purposes);

·       alias / nickname;

·       age range;

·       country of residence;

·       martial status; and

·       email address.

Some features of the Platform require Us to obtain Personal Data in order to provide those features. Such Personal Data may include (but is not limited to):

·       credit card information;

·       details of Expert consultations booked via the Platform;

·       any Personal Data (including information related to Your health status and sexual health wellbeing) that You upload to the Platform for sharing securely with Experts;

·       any Personal Data (including information related to Your health status and sexual health wellbeing) that you provide in any pre-appointment questionnaire to help an Expert better understand Your health status prior to an Expert session booked via the Platform;

·       any Personal Data (including information related to Your health status and sexual health wellbeing) that You share or that is generated during Expert sessions booked via the Platform;

·       any Personal Data that You provide when contacting Our customer support team (either on the phone or through the Platform) in relation to the Platform;

·       any Personal Data that You provide when filling in any forms (including contact form, registration forms, order forms, or payment forms) or when otherwise interacting with Us; and

·       any Personal Data that You share with Us when completing surveys and questionnaires on the Platform.

By using the Platform, We may also collect or generate other Personal Data about You, including:

·       technical details of Your use of the Platform to understand how You engage with and navigate the Platform and its features; and

·       information about Your computer or mobile device, such as the type of device You are using, Your network location, Your operating system, browser information, and/or Your IP address.

We may also collect Your Personal Data if You attend an event organized by, or linked to Us.

2.    How We use the Personal Data We Collect

We use Your Personal Data for various reasons. As a user of the Platform, the main reason We use Your Personal Data is to provide You with access to the Platform and to allow You to use and access its features.

More generally, We may collect, use, and disclose Your Personal Data for the following reasons:

·       to set You up as a registered user of the Platform and to customize Your account;

·       to connect You with Experts who are licensed to provide You with health information and services;

·       to provide You with information regarding Our digital content services;

·       to maintain and improve the Platform and/or the services or information made available via the Platform;

·       to understand feedback on the Platform and its features;

·       to effectively and efficiently manage and administer the operation of Our business;

·       to perform internal regulatory, administrative and operational requirements, including, for example, to prevent abuse of the Platform, to troubleshoot software bugs and operational problems, to conduct data analysis, and to monitor and analyze usage and activity;

·       to communicate with You in order to provide You with services or information about the Platform;

·       where applicable, to send announcements, surveys and/or marketing to You in relation to the Platform and in order to make You aware of ongoing or new campaigns, programs, initiatives and services that may be of interest to You;

·       for the administration and maintenance of databases storing Your Personal Data;

·       to enforce, apply, or notify You of changes to Our agreements with You; and

·       to comply with, and in order to assess and maintain compliance with, applicable laws, regulations, orders, and internal policies and procedures, and to cooperate with governmental investigations.

In each case, We ensure that Our usage of Your Personal Data complies with applicable laws.

For the avoidance of doubt, NAWAT does not record any teleconsultations You attend with Experts. You also have the ability to delete any records of chats You have with an Expert from Your archive.

3.    Marketing and Opt-Out

We would like to provide You with information about the Platform and services that We think may be of interest to You.

We conduct direct marketing activities in accordance with all applicable laws and so where You provide Your consent, We may contact You via phone, text message or email.

If at any time You do not want to receive any direct marketing communications from Us, You can opt out at any time by contacting Us using the contact details provided below or by following the unsubscribe link in one of Our marketing messages.

We do not provide Your Personal Data to external organisations for their own marketing purposes without Your consent.

4.    Storage and Processing

If You are a user of the Platform based in the United Arab Emirates, Your Personal Data collected through the Platform will be stored on servers or facilities located inside the United Arab Emirates.

If You are a user of the Platform based outside of the United Arab Emirates, to the fullest extent permitted by law, Your information collected through the Platform may be stored and processed in any other countries where NAWAT maintains facilities or where Our servers are located.

We will retain Your Personal Data in accordance with Our internal records retention and management policies and procedures for the length of time needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted under applicable laws. Even if You choose to close Your NAWAT account, We may be required to retain Your Personal Data in order to comply with Our legal obligations and regulatory requirements.

 Where We anonymize Your Personal Data for research or statistical purposes, We may use this information indefinitely without further notice to You.

5.    Disclosure of Your Personal Data

 We are committed to protecting Your privacy and will not disclose Your Personal Data to any third party, including Experts on Our Platform, unless required by law or as explicitly stated in this Privacy Policy.

 We may share Your Personal Data with Experts as necessary for the purposes of the healthcare services that they provide to You. However, You have the autonomy to decide whether or not to share Your sensitive information with the Experts on Our Platform during any consultation.

 Where required, We may also share Your Personal Data as noted below: 

·       With Our corporate entities. We may share information with any holding company, group company, and subsidiary within the NAWAT group of companies;

·       For Legal reasons. We may share information about You with third parties for legal reasons, if We reasonably believe that disclosing the information is needed to: (1) comply with any valid legal process, governmental request, court order, applicable law, rule, or regulation; (2) investigate, remedy, or enforce potential violations of the Terms; (3) protect the rights, property, and safety of Us, Our Users, or others; (4) detect and resolve any fraud or security concerns;

·       With third parties as part of a merger or acquisition. If NAWAT becomes involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of Our business to another company, We may share Your Personal Data with that company before and after the transaction closes; and

·       With Non-Profit Organizations (NGOs). Where You have been referred to the Platform by an NGO, information relating to Your use of the Platform may be accessed by, and shared with, the administrator responsible for that NGO.

All credit/debit cards details and personally identifiable information will not be stored, sold, shared, rented, or leased to any third parties. Experts will not have access to any debit/credit card details. We follow the industry’s standards to protect Your details during transmission once received, but You should be aware that no method of electronic transmission or storage is 100% secure. We can therefore not be held responsible for the unlikely circumstances where information is accessed without authorization.

6.    Your Rights 

Where We collect, use or store Your Personal Data, You may also have the ability to exercise these rights via the Platform. These rights include:

Access	You have the right to obtain information regarding the processing of Your Personal Data and access to the Personal Data which We hold about You. You can also access certain information, such as your medical records (if uploaded), and consultation history, via your account on the Platform.
Consent Withdrawal	You have the right to withdraw Your consent to the processing of Your Personal Data at any time (including with respect to Us using Your Personal Data for marketing purposes). Please note, however, that We may still be entitled to process Your Personal Data if We have another legitimate reason for doing so. For example, We may need to retain Personal Data to comply with a legal obligation.
Rectification	You have the right to require Us to correct any inaccuracies in Your Personal Data. You may also update inaccurate or incomplete Personal Data via Your account on the Platform.
Erasure/Deletion	You have the right to ask Us to erase Your Personal Data in certain circumstances. Deletion of Personal Data will be carried out on the understanding that the removal of some information may negatively affect Your ability to use the Platform. There may also be circumstances where You ask Us to erase Your Personal Data but We are legally entitled to retain it.
Objection/Restriction	You have the right to object to, or request that We restrict, the processing of Your Personal Data in certain circumstances. Again, there may be circumstances where You object to, or ask Us to restrict, Our processing of Your Personal Data but We are legally entitled to refuse that request.
Portability	In some circumstances, You have the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that We transmit or transfer Personal Data You have given Us to another organization where this is technically feasible.
Complaint	You have the right to lodge a complaint with the relevant data protection regulator if You think that any of Your rights have been infringed by Us.

If You do wish to exercise any of the rights set out above, please contact Admin@nawathealth.com and We will respond to Your request within the timeframes prescribed by applicable laws. 

You will not be required to pay a fee to exercise Your rights, save for where such request is determined to be manifestly unfounded or excessive in which case a reasonable fee may be imposed, or We may refuse to act on the request. 

7.    Security Measures 

We have implemented and will maintain appropriate technical and organizational measures to safeguard the Personal Data that We control from unauthorized or unlawful processing, accidental loss, destruction, damage, alteration, or disclosure. Specifically, We utilize encryption technologies to further secure the Personal Data We handle. We will promptly notify You and any applicable supervisory authority of any data security breach in compliance with Our legal obligations. 

You are solely responsible for maintaining the confidentiality of Your account details, including Your password. If You have any concerns about the security of Your account, You should inform Us immediately. We reserve the right to deactivate or suspend Your account at any time, without notice, if We suspect any unauthorized use of Your account or a breach of Our Terms. 

8.    Mobile Push Notifications/Alerts 

We may send push notifications or alerts to Your mobile device after obtaining Your consent to do so. You can deactivate these messages at any time by changing the notification settings on Your mobile device. You must withdraw from providing push notifications or alerts or using such features in addition to adjusting the notifications in Your mobile device if You do not want to receive these push notifications or alerts. 

9.    Payments Details 

In case of services requiring payment, We request credit/debit card or other payment account information, which will be used solely for processing payments. Your purchase transaction data is stored only as long as is necessary to complete Your purchase transaction. Once that is complete, Your purchase transaction information is deleted. Where necessary for processing future payments, and subject to Your prior consent, Your financial information will be stored in encrypted form on secure servers of Our payment gateway service provider, Stripe, who, as a payment gateway, is beholden to treating Your Personal Information per its policy. All direct payment gateways adhere to the latest security standards managed by the PCI Security Standards Council, a joint effort of brands like Visa, MasterCard, American Express, and Discover.

 10.  Disclaimer and the Role of NAWAT 

You acknowledge and agree that NAWAT is not a healthcare provider and NAWAT’s role is limited to an intermediary, facilitating and ensuring a confidential relationship between You and the Experts. We provide You with programs crafted by Experts and facilitate teleconsultations with them. However, it is important to note that NAWAT is not responsible for delivering or overseeing any teleconsultation provided by the Expert and NAWAT, its officers, directors, employees, and agents shall not be held liable for any teleconsultation, advice, or information provided by the Expert. This includes, but is not limited to, inaccuracies, errors, omissions, or misrepresentations in consultations, false responses, false medications, or any other actions or inactions of the Expert. The Expert assumes full responsibility for the content and consequences of their advice.

 11.   Cookies and Similar Technologies 

A browser cookie is a small piece of data that is stored on Your device to help websites remember things about You. Other technologies, including web storage and identifiers associated with Your device, may be used for similar purposes. In this Privacy Policy, We use “Cookies” to refer to all of these technologies. 

Like most online services and websites, We may use Cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about Your activity, browser, and device. 

We may also use these Cookies to collect information when You interact with the Services We offer through Our partners, such as advertising and commerce features. Most web browsers are set to accept Cookies by default. You can choose to remove or reject browser Cookies through the settings on Your browser or device. Keep in mind, though, that removing or rejecting Cookies could affect the availability and functionality of Our Platforms.  

Like most providers of online services, NAWAT uses Cookies for a number of reasons, such as protecting Your data, helping Us see which features are most popular, counting Visitors to a page, improving Our Users’ experience, keeping Our Platform secure, and generally providing You with a better, more intuitive and satisfying experience. The Cookies We use generally fall into one of the following categories: (1) preferences: We use these Cookies to remember Your settings and preferences (for example: language); (2) security: We use these Cookies to help identify and prevent security risks (for example: to store Your session information, and to prevent others from changing Your password without Your username and password); (3) performance: We use these Cookies to collect information about how You interact with Our Platform and to help Us improve them (for example: to determine if You have interacted with a certain page); (4) analytics: We use these Cookies to help Us improve Our Platform (for example: to learn more about which features are the most popular with Our Users and which ones might need some tweaks); and, (5) advertising: We use these Cookies to deliver advertisements, to make them more relevant and meaningful to consumers, and to track the efficiency of Our advertising campaigns on Our Platforms.

 12.  Limitation to Our Privacy Policy  

Our Platform may contain links to other websites or services which are not within Our control. We are not responsible for such websites’ privacy practices or content. Please understand that any information that is disclosed in these areas becomes subject to the privacy policies and practices of those sites. We have no control over its use, and You should exercise caution when deciding to disclose Your Personal Data. 

13.  How to Contact Us 

If You have any questions or comments about this Privacy Policy, the Platform, or the way We process Your Personal Data, You may contact Us through the following email address at: info@nawathealth.com