At Shifaam our mission is to put an accessible and affordable health service in the hands of every person on earth. We are passionate about high-quality and convenient healthcare. We are also passionate about privacy. We strive to comply with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA), and to be market leaders when it comes to healthcare and privacy.
We invite you to spend a few moments understanding this policy. We may update this policy from time to time and, if we make any material changes, we will notify you when we do so. We will provide you with the opportunity to review such changes. By continuing to use our products and services after the changes have been made and we have notified you of them, the way we use your personal data will be subject to the terms of the updated policy.
This policy covers:
Who we are;
What personal data we hold and how we get it;
What we use your personal data for;
Sharing your personal data;
Data security and transfers; and
If you have any further questions about how we process your information, please don't hesitate to get in touch by contacting us at email@example.com
Who we are
Our healthcare services are delivered by Shifaam. The registered office and principal place of business is 2nd Floor, Citi View Tower, Shaheed-e- Millat Road, Karachi, Pakistan.
Your relationship is with Shifaam Healthcare Services Limited. When this policy talks about ‘Shifaam’, ‘us’ or ‘we’, it means Shifaam Healthcare Services Limited. We provide your data to other companies or Companies within our corporate group, who are our business partners and are linked to us in providing our healthcare services.
What personal data we hold and how we get it
We use the following categories of personal data:
Personal details: When you register with us, you complete forms and provide us with basic information about yourself, such as your name, date of birth, physical address and email address. You will also provide us with a copy of identification documentation for ID checks to be carried out by one of our commercial partners.
Health and medical information: The main type of information we hold about you is health and medical information: information about your health, symptoms, treatments, consultations and sessions, medications and procedures. This includes details of your consultations with our doctors, and interactions with our digital services.
We get some of this information directly from you, when you register with us and when you use our healthcare services. Any correspondence we receive from you is uploaded electronically to your Shifaam medical record. We retain recordings of our consultations with us, these recordings are held securely in accordance with our retention policy for legal purposes only. No one can access these recordings of your consultations unless needed to in case any legal matter arises.
We may also hold information about you and your health from other apps, devices and services where you have given your consent to that data being shared with us. Examples include where you decide to share information collected from a smart watch or similar device with our App.
Financial information: If you make any payments on the Website/App, your credit/debit card details are processed directly by a third party processor that will store all payment information and transaction details. We will only retain details of transactions on secure servers and we will not retain your credit or debit card information.
Technical information and analytics: When you use our Website/App, we may automatically collect the following information where this is permitted by your device settings:
(a) technical information, including the address used to connect your mobile phone or other device to the Internet, your login information, system and operating system type and version, browser or app version, time zone setting, operating system and platform, and your location (based on IP address); and
(b) Information about your consultation, including products and services you viewed or used, App response times, interaction information (such as button presses) and any phone number used to call our customer service number.
We work with partners who provide us with analytics and advertising services (for our services only and not for third party advertising). This includes helping us understand how users interact with our services, providing our advertisements on the internet, and measuring performance of our services and our adverts. Cookies and similar technologies may be used to collect this information, such as your interactions with our services.
Information obtained from third party services: You may choose to connect your existing accounts with other providers (such as a social media provider) to your account with us. This may, for example, make it easier to create an account with us. If you choose to do this, we will receive limited information about you from that provider, such as your email address, name, and other sign-up related details.
What we use your personal data for
The purposes for which we use your personal data and the legal grounds on which we do so are as follows:
We obtain and use your personal details and financial details in order to establish and deliver our contract with you.
We obtain and use your medical information because this is necessary for medical purposes, including medical diagnosis and the provision of healthcare or treatment. This includes the information collected through our consultations with you (such as notes and recordings), our digital services, and medical history from your Shifaam Medical Record. It may also include sharing information with other healthcare professionals as necessary for the provision of care to you, such as specialist referral services, therapists, pharmacists, hospitals, accident and emergency services, pathology service providers, and diagnosis centers chosen by you for the purpose of imaging request forms.
Where you have provided your explicit consent, we will use your medical information (always having removed personal identifiers, such as your name, address and contact details) to improve our healthcare products and services, and our artificial intelligence system, so that we can deliver better healthcare to you and other Shifaam users. This medical information (de-identified in the way described above) may include your medical record (both records received and created by us), transcripts and recordings of your consultations, and your interactions with our artificial intelligence services, such as our symptom checker. This does not involve making any decisions about you – it is only about improving our products, services and software so that we can deliver a better experience to you and other Shifaam users, and help achieve our aim of making healthcare affordable and accessible to everyone. Strict confidentiality and data security provisions apply at all times.
We may use strictly anonymized information (including medical information) to improve our healthcare products and services.
We may obtain and use data about your precise location where you give your consent (through providing us access to your location), for example, to help direct you to the nearest pharmacy. We may also derive your approximate location from your IP address.
We use your email address and/or phone number to contact you with occasional updates and marketing messages where you have not opted out, based on our legitimate interest in marketing our services to you and subject to your right to opt out at any time.
Based on our legitimate interest in managing and planning our business, we may analyze data about your use of our products and services to, for example, troubleshoot bugs within the App, forecast demand of service and to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you - it is only about improving our Website/App so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.
Where necessary, we may need to share personal and financial details for the purposes of fraud prevention and detection.
We also store your medical information, such as notes from consultations, recordings of our consultations with you and your interactions with our digital services, for safety, regulatory, and compliance purposes. For example, we may need to review your information and, where necessary, make disclosures in compliance with reasonable requests by regulatory bodies including the General Medical Council, MHRA, and Care Quality Commission, or as otherwise required by law or regulation.
Where necessary for safety, regulatory and/or compliance purposes, we may audit consultations and your other interactions with our services. Strict confidentiality and data security provisions will apply at all times to any such audit and access.
We may use non-personal data (data from which an individual cannot be identified) to improve our products and services.
Sharing your personal data with others
We may share your personal data with members of our corporate group and our partners to help us deliver our services to you.
We may share your personal data with companies we have hired to provide services on our behalf, including those who act as data processors on our behalf. Those data processors are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us.
We may share with our commercial partners aggregated data that does not personally identify you, but which shows general trends, for example, the number of users of our service.
Where you access our services through your health insurance provider or any of our commercial partners (including your employer) we may share with such partner your name, date of birth, email address, policy number, location, and the fact you have registered/used the service (and any other similar information). We will not without your consent share any details relating to the content of your consultation with us or your health/medical records. With your consent, we may share the date of the appointment, details of your diagnosis, prescription, and pharmacy location, whether or not you had a referral made and other similar information about your appointment with us.
We will, where necessary for your treatment or care, share your information with your other health and social care providers. For example, specialist referral services, therapists, pharmacists, hospitals, accident and emergency services, pathology service providers, diagnosis centres chosen by you for the purpose of imaging requests, and other health and care bodies. This may include sharing information with such services for safeguarding purposes in accordance with our legal obligations.
We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person.
Except as described above, we will never share your personal information with any other party without your consent.
We retain your medical records in accordance with national best practice guidance – we retain Medical Records and information 10 years after the date of the last contact; or 5 years after the patient's death if sooner.
Data storage, security and transfers
We do not store your personal health data on your mobile device. We store all your personal health data - including your primary care information, medication information and diagnostic information - on secure servers.
Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
We do not store any credit or debit card information. Payments are processed via a third party payment provider that is fully compliant with Level 1 Payment Card Industry (PCI) data security standards. Any payment transactions are encrypted using SSL technology.
Your data may be processed or stored via destinations outside of the Pakistan and the South Asia Area, but always in accordance with data protection law, including mechanisms to lawfully transfer data across borders, and subject to strict safeguards. For example, we work with third parties who help deliver our services to you, whose servers may be located outside the above mentioned areas.
As indicated above, whenever we rely on your consent to process your personal data, you have the right to withdraw your consent at any time by accessing the privacy settings in the App.
You also have specific rights are as below:
Wherever we process data based on your consent, withdraw that consent at any time. You can do this via the privacy section of our App;
Understand and request a copy of information we hold about you. Recordings of your appointments with us and other medical notes can be accessed via the App. For other information, you can make a request by email;
Ask us to rectify or erase information we hold about you, subject to limitations relating to our obligation to store medical records for prescribed periods of time;
Ask us to restrict our processing of your personal data or object to our processing; and
Ask for your data to be provided on a portable basis.
For any questions or concerns, you can contact us by sending an email to firstname.lastname@example.org