This policy (together with our Consumer Terms and Conditions (the "Terms") and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. Any terms used in this policy shall have the same meaning as those used in the Terms. In the unlikely event of any conflict between the Terms and this policy, the Terms shall prevail.
By agreeing to the Terms you are accepting and consenting to the practices described in this policy.
For the purpose of the General Data Protection Regulations (GDPR) and Data Protection Acts 1988 and 2003 (the "Acts"), the data controller[a] is Jinga Life of Office Pods, 6-7 Marine Road, Dun Laoghaire, Co Dublin (the “Company”).
By registering with Jinga Life and giving your personal data to us, you indicate your explicit consent for us, and those organisations directly involved in delivering our service, to collect, use, store, disclose and otherwise process your personal data in accordance with the service we provide to you, our Terms and within the scope of this policy.
Personal Information we may collect from you
We may collect and process the following data about you:
Information you give us and we collect about you.
You may give us information about you by entering information through the Application (the App), allowing us access to data about you held by third parties, filling in forms, or by corresponding with us by phone, e-mail or otherwise. You may also give us information, and we may collect and process information about you resulting from any interactions you undertake or services you request or source through the App (including consultations, tests and prescriptions) and via any health or monitoring device you connect to the App. Information collected includes any data or information contained in consultation recordings. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph, and may also include sensitive information about you including your health, medical records, physical and mental performance, characteristics, any ailments, diseases or disabilities, your race, gender, age and other sensitive information. Information automatically collected by our App.
With regard to each of your visits to our App, we may automatically collect the following information where this is permitted by your device settings:
1. 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, time zone setting, operating system and platform, your location; and
2. information about your visit, 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.
Information we receive from other sources.
We may receive information about you if you use any of the other services or products that we provide, or if you use any of our Affiliates or third parties to fulfil a request you have made via the App.
Use of Personal Information
We use information held about you in the following ways:
1. provide the products and services;
2. provide such information to any member of our group, or Affiliates, business partners, suppliers and subcontractors of the Company where reasonable or necessary in relation to the provision of the products and services requested by you including provision of your information to Practitioners (including nurses, GPs, specialists), dispensing chemists, partner diagnostic (testing) providers, and suppliers or subcontractors used in relation to our App;
3. process your payment for such products and services;
4. review and enhance the quality of our services and products, including monitoring compliance with clinical care standards;
5. make disclosures as required by or in compliance with legal requests by regulatory bodies including the Irish Medical Council or the Health Information and Quality Authority (HIQA), or as otherwise required by law or regulation;
6. where you request it or have otherwise consented, provide to your insurance company/ies who may contribute to the cost of the products or services you request to use;
7. where you request it, provide to your other healthcare providers such as your GP; and
8. assist in the detection of fraud where we are legally obliged to provide information to a policing or regulatory authority.
Other Uses of Personal Information
We may use this information:
1. to administer and improve our App and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes. Statistical and survey data and results will be anonymised;
2. to improve our App to ensure that content is presented in the most effective manner for you and for mobile phone or other device usage;
3. to allow you to participate in any interactive features of our service, when you choose to do so;
4. for purposes including research and marketing of the Jinga Life service, subject to such data being anonymised; E.g. A marketing campaign could include information such as the gender and age ranges of our clients, most common uses of our App and services etc.
5. as part of our efforts to keep the App safe and secure and to protect your information from outside threats; and
6. to make suggestions and recommendations to you and other users of our App about services that may interest you or them.
We may combine this information with information you give to us and with information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
By using the App or any of the Services, you consent to us collecting and using technical information about the devices and related software, hardware and peripherals for services that are e-based or wireless to improve our products and to provide any services to you.
If you use our services, you consent to us and our Affiliates' and licensees' transmission, collection, maintenance, processing and use of your location data and queries to provide and improve location-based products and services. You may withdraw this consent at any time by turning off the location services settings on your device.
If Jinga Life Limited or all of its assets are substantially acquired by a third party, personal data held by Jinga Life about its customers will be one of the transferred assets. You will be informed in advance in the event of this occurring.
We may disclose your personal information if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of Jinga Life Limited, our customers, or others. This includes exchanging information with other organisations for the purposes of fraud protection.
Storage and Security of Personal Information
We do not store your personal health data on your mobile device. We store all your personal health data – including your primary care information, secondary care information, medication information and diagnostic information securely in the cloud, protected by world class industry standard protocols and compliant with Irish and European data protection obligations. 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 Secure Socket Layer (SSL) technology.
Your Access to Your Personal Information
In line with GDPR, the Freedom of Information Act 2014 (FOI) and the Data Protection Acts 1988 and 2003, you have the right of access to any Personal Information about you which we hold by sending in a signed written request to Jinga Life Limited, OfficePods, 6-7 Marine Road, Dun Laoghaire, Co. Dublin, A96 P9H6, or to firstname.lastname@example.org. A fee not greater than that allowed in legislation may be charged for processing this.
To ensure that Jinga Life Limited satisfies itself about the identity of the person making a request for their personal information and so that it does not disclose personal data to a party who is not entitled to it under the Data Protection Acts or FOI, the person making the request will need to provide Jinga Life Limited with their name, address(es), date of birth and any customer identification numbers that they have along with a copy of their photo identification. You also have the right to require us to correct any inaccuracies in the information we hold about you by sending us a written request with proof of the inaccuracy for correction.
Changes to this Statement
If you have elected to receive marketing materials, at any time subsequently you can ask not to receive marketing materials. You can exercise this right by contacting us at to Jinga Life Limited, OfficePods, 6-7 Marine Road, Dun Laoghaire, Co. Dublin, A96 P9H6 or at email@example.com.