Privacy Policy

Introduction

WeCare Tech Limited respects and is committed to protecting your privacy and personal data.

This Privacy Policy will help you understand how we use and protect your personal data which you provide to us and which we collect through our website (www.wecare-app-net) or mobile applications (the “Platform”) when you use and access our Platform and our services available on the Platform comprising a directory of segmented home healthcare, nutrition and wellbeing service providers (each a “Care Provider”) in Jordan, Saudi Arabia, Egypt, United Arab Emirates, and Canada (the “Directory”); (b) a Care Provider appointment booking facility (the “Appointment Booking Facility”); (c) a real live real time video, audio and instant messaging facility for online consultations between you and Care Providers (the “Online Consultation Facility”); and (d) general non-specific health tips and blogs for educational and informational purposes (the “Blogs”, and together with the Directory, the Appointment Booking Facility, the Online Consultation Facility and such other services we may provide on or from the Platform from time to time, the “Services”). If you have any questions, feel free to contact us at dpm@wecare-app.net.

This Privacy Policy sets out the basis on which any personal data we collect from you or other sources or that you provide to us (“Personal Data”) will be processed by us in connection with your access and use of the Platform and the Services. We understand the importance you place on the Personal Data, and we are committed to protecting your privacy and Personal Data. Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.

WeCare Tech Limited, of Desk D51, 15th Floor, Al Sarab Tower, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, United Arab Emirates is the controller and is responsible for your Personal Data (collectively referred to as “Company”, “we”, “us” or “our” in this Privacy Policy. References to “user” or “you” (or similar) are references to you as an individual or legal entity, as the case may be. If you have any queries in relation to our Privacy Policy or your Personal Data, please contact us at dpm@wecare-app.net.

We keep our Privacy Policy under regular review. This version was last updated on 16^th November 2020. Our business changes constantly, and our Privacy Policy may therefore also need to change. We will post the current version of this Privacy Policy on the Platform and each such change will be effective upon posting on the Platform or upon the date designated by us as the “effective date”. We may e-mail periodic reminders of our notices and conditions, but you should check our Platform frequently to see recent changes. It is your obligation to regularly check the Privacy Policy. Your continued use of the Platform following any such change constitutes your agreement to this Privacy Policy as so modified from time to time.

Care Providers and other third parties who have registered and entered into a subscription agreement with us in relation to the Appointment Booking Facility available on the Platform, may be subject to an additional provision as to how we will use Personal Data as set out in such separate contractual arrangements or binding rules.

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 your relationship with us.

If you use our Platform and the Services, you consent to the collection, use and sharing of your Personal Data under this Privacy Policy (which includes all other documents referenced in this Privacy Policy) and agree to our applicable Terms of Service for the Platform. We created this Privacy Policy to give you confidence as you use the Platform and Services and to demonstrate our commitment to your privacy and Personal Data.

Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or services, such as contact and location Data. Please check these policies before you submit any Personal Data to these websites or use these services.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of this Privacy Policy here: LINK TO PDF WeCare PRIVACY POLICY.

The data we collect about you
How is your personal data collected
How we use your personal data
Disclosures of your personal data
International transfers
Data security
Data retention
Your legal rights
Glossary
Description of categories of personal data

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data.
Contact Data.
Financial Data.
Care Provider Data.
Transaction Data.
Device Data.
Content Data.
Profile Data.
Usage Data.
Marketing and Communications Data.
Location Data

We explain these categories of data here LINK TO DESCRIPTION OF CATEGORIES OF PERSONAL DATA BELOW.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered personal data in 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 Platform 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.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Platform, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Platform, download our mobile application, subscribe to any of the Services, search for the Platform or a Service, share data via the Platform’s social media functions, and when you report a problem with the Platform or Services. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you visit the Platform we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy LINK TO WECARE COOKIE POLICY for further details.
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. 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.
Information we receive from other sources including third parties and publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:
Device Data from the following parties:

analytics providers;

advertising networks; and

search information providers.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services; and
Identity, Contact and Care Provider Data from publicly available sources.

We use cookies and/or other tracking technologies to distinguish you from other users of the Platform and to remember your preferences. This helps us to provide you with a good experience when you use the Platform and also allows us to improve the Platform. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy LINK TO WECARE COOKIE POLICY.

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:

Where you have consented before the processing.
Where we need to perform a contract, we are about to enter, or have entered, with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Click here LINK TO GLOSSARY: LAWFUL BASIS to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity	Type of data	Lawful basis for processing
To list you as a Care Provider	Care Provider	Necessary for our legitimate interests (to keep our records updated and to provide our services to our customers)
To install our mobile application and register you as a new user	Identity Contact Financial Device	Your consent
To process in-Platform purchases and facilitate Services including managing payments and collecting money owed to us	Identity Contact Financial Transaction Device Marketing and Communications Location	Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the Platform or any Services	Identity Contact Financial Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey	Identity Contact Device Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and the Platform App including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the Platform	Identity Contact Device Content Profile Usage Marketing and Communications Location	Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)
Deal with legal disputes and claims	Identity Contact Care Provider Financial Transaction Marketing and Communications	Legitimate interests (we have a legitimate interest in being able to deal with disputes and legal claims)
Comply with a legal obligation, like a court order requiring us to release information	Identity Contact Care Provider Financial Transaction Marketing and Communications	Compliance with a legal obligation

Disclosures of your personal data

When you consent to providing us with your Personal Data, you consent to share your Personal Data with the third parties set out below for the purposes set out in the table above:

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

International transfers

The Personal Data that we collect from you may be transferred to, and stored at, a destination outside of the jurisdictions in which the persons to whom such Personal Data relates being Jordan, Saudi Arabia, Egypt, United Arab Emirates, and Canada (the “Directory”). It may also be processed by external third parties that are based outside of such jurisdictions.

Whenever we transfer your Personal Data outside of such jurisdictions or to third parties, we ensure a similar degree of protection is afforded to it by ensuring either that we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for your Personal Data by the European Commission, or we may use specific contractual obligations, which give your Personal Data the required level of protection.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using 3D-Secure technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your device using application data caches and browser web storage (including HTML) and other technology.

Certain Services may include social networking, chat room or forum features. Ensure when using these features that you do not submit any Personal Data that you do not want to be seen, collected or used by other users.

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

Generally, we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

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.

If you do not use the Platform for a period of twelve months, then we will treat the account as expired and your Personal Data may be deleted.

Your legal rights

Under certain circumstances you have the following rights in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer or your personal data.
Right to withdraw consent.

You also have the right to ask us not to continue to process your Personal Data for marketing purposes.

You can exercise any of these rights at any time by contacting us at dpm@wecare-app.net.

Glossary

Lawful Basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Internal Third Parties

Other companies in our group, who may be acting as joint controllers or processors, and who are based in Jordan, Saudi Arabia, Egypt, United Arab Emirates, and Canada (the “Directory”) and provide IT and system administration services and undertake leadership reporting.

External Third Parties

Service providers, who may be acting as processors based in Jordan, Saudi Arabia, Egypt, United Arab Emirates, and Canada (the “Directory”) who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Jordan, Saudi Arabia, Egypt, United Arab Emirates, and Canada (the “Directory”) who provide consultancy, legal banking, accounting and insurance services.

Regulators and other authorities acting as processors or joint controllers based in Jordan, Saudi Arabia, Egypt, United Arab Emirates, and Canada (the “Directory”) who require reporting of processing activities in certain circumstances.

In the case of:

Care Provider Data, to our users through our Platform;
Identity and Contact Data, to Care Providers with whom you have booked appointments through our Platform; and
Identity, Contact, Financial Data and Transaction Data, to Care Providers with whom you have booked appointments for online consultations through our Platform.

Your legal rights

You have the right to:

Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
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.
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.

(Steps: By entering the settings box in the application, then clicking on the DELETE account bottom, then confirming and then specifying the reason for deleting the account).

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and 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 object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
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:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful, but you do not want us to erase it;
- 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
- you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your Personal Data to you or 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. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us by email at dpm@wecare-app.net.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other 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.

We try to respond to all legitimate requests within one month. Occasionally, it might take us longer than one month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

10 Description of categories of personal data

Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
Contact Data: billing address, delivery address, email address and telephone numbers.
Financial Data: bank account and payment card details.
Care Provider Data: title and full name, locations, relevant expertise, procedures, languages spoken, accepted forms of payment, and education. In addition, Care Providers that enter into a separate subscription agreement with us, medical insurance policies which are accepted by such Care Provider and all local registration and licence details.
Transaction Data: includes details about payments to and from you and details of in-Platform purchases.
Device Data: includes the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, language and time zone setting.
Content Data: includes information stored on your device, including login information, photos, videos or other digital content, and check-ins.
Profile Data: includes your username and password, in-Platform purchase history, your interests, preferences, feedback and survey responses.
Usage Data: includes details of your use of our Platform including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Data: includes your current location disclosed by GPS technology.

Note in relation to online consultations:

During the course of any online consultation with a Care Provider, which is held on or via our Platform, you may exchange with such Care Provider through the Platform special personal data including in relation to health (health history, symptoms, examinations and tests and the results thereof, diagnosis, treatment and care plan), ethnicity, sexual orientation, sex life, religious beliefs or opinion or genetic data as relevant to the Care Provider. This information is held and used by the Care Provider in accordance with its own privacy policy, terms and conditions and applicable laws and regulations. It is your responsibility to request for and consent to the privacy policy and terms and conditions of such Care Provider. We do store such information on our systems but delete such information (if shared via the Platform) from our systems after the end of each online consultation.