Privacy Policy

MEGI HEALTH UK LTD Privacy Policy

Our Privacy Policy was last updated May 2024.

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when you use the Service and tells you about Your privacy rights and how the law protects you.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• "Account" means a unique account created for You to access our Service or parts of our Service.
• "Company" (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to MEGI HEALTH UK LTD For the purpose of the GDPR, the Company is the Data Controller.
• "Country" refers to the Kenya.
• "Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• "Data Controller", for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• "Device" means any device that can access the Service such as a computer, a cell phone or a digital tablet.
• "Personal Data" is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
• "Service" refers to the MEGI Website accessible at https://www.megi.ai and the MEGI Virtual Assistant accessible via WhatsApp upon receipt of an invitation link.
• "Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
• "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• "You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Our Contact Details

Name: MEGI HEALTH UK LTD

Address:
1-3 Worship Street,
C/O Buckworths,
2nd Floor,
London, England,
EC2A 2AB

E-mail:
privacy@megi.ai

Megi AI is registered as a Data Controller, as a franchise of SYN Sigma Consulting, with the Office of the Data Protection Commissioner (ODPC) under the Data Protection Act, 2019. We are committed to complying with the Kenyan data protection legal framework and ensuring the responsible processing of personal data of Kenyan residents.

Collecting and using your personal data

Types of data collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• First name
• Last name
• Phone number
• E-mail
• Date of birth
• Gender
• Address
• Personal identification number
• Referrer
• Height
• Weight
• Hip circumference
• Waist circumference
• Employment status
• Occupation
• Race
• Diagnosis
• Medication
• Blood pressure readings
• Next doctor appointment date and appointment hospital
• Difficulties
• Food and drinks intake
• Physical activity
• Mood
• Sleep quality
• Doctor screening statuses
• Doctor recommendation
• Doctor notes
• Blood pressure reading graphs
• Doctor appointment records
• Therapy adherence
• Stress level information
• Cholesterol
• Smoking information
• Reports of pharmacovigilance
• Medical data voluntarily disclosed by you

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies: A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
  Type: Session Cookies
  Administered by: Us
  Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
• Cookies Policy / Notice Acceptance Cookies
  Type: Persistent Cookies
  Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
• Tracking and Performance Cookies
  Type: Persistent Cookies
  Administered by: Third-Parties
  Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

Use of your personal data

The Company may use Personal Data for the following purposes:

• Improve the Service and cater communication with You.
• Remind You to take Your medications and measure your blood pressure, create reports based on aggregated Users’ data, educate you on hypertension, inform you what to do in case of difficulties, and provide You with a maximally informed status on your hypertension.
• To provide and maintain our Service, including to monitor the usage and engagement of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct 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 Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• We share this information with our partner medical institution. Furthermore, we will share the data about pharmacovigilance reports with relevant pharmaceutical companies.
• Also, we might produce a report based on the aggregated users’ data. The nature of such a report is that an individual user cannot be identified and that any individual is unidentifiable.
• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You. Further details of processing can be found below.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

How we store your personal data

Retention of Your Personal Data

Your information is securely stored. The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Thereafter, we will dispose of your information by making them unidentifiable. However, we will keep such anonymised data for future scientific research.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Security of Your Personal Data

We implement Privacy by Design and Default in our systems, ensuring that personal data is protected through the entire lifecycle. For any high-risk processing activities such as the use of AI to generate personalized health insights, we conduct a Data Protection Impact Assessment (DPIA) in line with Regulation 40 of Kenya’s Data Protection (General) Regulations, 2021.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies. We utilize third-party APIs from companies such as Infobip and OpenAI and have signed BAAs to implement zero-retention policies to maximize your privacy where possible.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy.

Legal basis for processing under the GDPR

• Consent - You have given Your consent for processing Personal Data for one or more specific purposes. You are able to remove your consent at any time. You can do this by contacting privacy@megi.ai
• Legitimate interests - Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing.

Your Rights under Kenya's DPA

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. Under the Kenya Data Protection Act, 2019, you have the following rights regarding your personal data:

Your right of access - You may request a copy of the personal data we hold about you within 7 days of such a request.

Your right to rectification - You may request correction or updating of inaccurate or incomplete data within 14 days.

Your right to erasure - You may request deletion of your data under specific legal grounds.

Your right to object  - You may object to the processing of your data on legitimate grounds.

Your right to data portability - You may request your data in a machine-readable format within 30 days.

Your right to restriction of processing - You may request that we limit how we use your personal data.

Your right not to be subject to automated decision-making without human involvement.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

You may exercise any of these rights by contacting our Data Protection Office at privacy@megi.a.

Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

Children's Privacy

We do not knowingly collect or process personal data of children under the age of 18 without verifiable consent from a parent or legal guardian, as required by the Data Protection Act (Section 33). Where we offer services directed toward minors, we implement age-verification and parental consent procedures.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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