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VHI ONLINE DOCTOR PRIVACY POLICY

WHAT IS VHI ONLINE DOCTOR

Vhi Online Doctor is a private healthcare service which enables patients to hold on-demand and by appointment; secure, high-definition, face-to-face, real-time; video, telephone, and online-chat/message consultations with “Healthcare Providers” including; Irish Medical Council (“IMC”) registered General Practitioners

Vhi Online Doctor is not intended to replace the relationship with patients’ existing GP or Healthcare Providers. It is a complementary service offering the advantages of convenience and accessibility to a broad range of healthcare services. Vhi Online Doctor is not an emergency service provider.

Vhi Online Doctor charges via a or pay-as-you-go model (“Self-Pay”), or is paid in full or part by patients’ healthcare insurer, Vhi, or employer as part of a group scheme, or using a simple pre-paid coupon code.

OUR PRIVACY POLICY

This Policy applies as between you, the User of this Application (IOS or Android) or Website and Vhi Online Doctor, VideoDoc Limited and VideoDoc Technologies LTD (collectively “VideoDoc”), the provider of this Application (IOS or Android) and Website on behalf of Vhi Group DAC (herein after “Vhi”), a company registered in Ireland No.527605. Registered office: Vhi House, Lower Abbey Street, Dublin 1, Ireland.

This Policy applies to Our use of all data collected by us in relation to your use of the Application (IOS or Android) and Website. This Privacy Policy is dated 3rd January, 2017 and should be read in conjunction with Our VideoDoc Terms and Conditions and Medical Consent dated 3rd January, 2017.

By accepting Our Privacy Policy, you authorise the Healthcare Provider you will see and VideoDoc to use and release the treatment information (“sensitive information”) obtained during this consultation and held by VideoDoc for purposes of your treatment, payment, and ongoing health care. You consent that this release includes your primary GP, nominated pharmacy, any family or persons involved in your care. VideoDoc will only seek to share the minimum information necessary to your health insurer in order to assist with reimbursement. VideoDoc will only seek to share the minimum information necessary. If you do not wish us to release this information, please notify the General Practitioner. If you are entitled to free or subsidised consultations through Vhi, we will release your name, date of birth and policy number to Vhi to assist in reimbursement. We will not release information about your consultation without your express consent.

VideoDoc will only share with Vhi your first name, last name, date of birth and Vhi policy number to be reimbursed for any services you receive from us, without requesting your specific permission.

The Irish Medical Council, Guide to Professional Conduct and Ethics for Registered Medical Practitioners, 8th Edition 2016, guidance is to share telemedicine consultations with patient’s own General Practitioner (“GP”). We request, that on you print off, email, or fax your Consultation Reports to your own GP as part of this agreement.

Our customer satisfaction survey (“Survey”) is an optional, anonymous Survey. No personal data is collected along with the responses.

You agree that VideoDoc may use Anonymised Data in the improvement of its services and in the development of its services and its business including Vhi and third parties. In this context, Anonymised Data refers to data from which the patient cannot be identified.

The Vhi Online Doctor Service is provided by VideoDoc Limited.

DEFINITIONS AND INTERPRETATION
Definitions and Interpretation
In this Privacy Policy, unless the context otherwise requires, the following expressions have the following meanings:

1.1 “VideoDoc /Our/Us” means VideoDoc Limited, 8 The Mall, Beacon Court, Sandyford, Dublin 18, D18 C2D0, Ireland;

1.2 “User” means any patient, customer, healthcare provider (registered IMC General Practitioners,) or carer that accesses the Apps and Websites or Orders Products and Services from Vhi Online Doctor or any of its subsidiaries or affiliates and is not directly employed by VideoDoc or acting during their Vhi Online Doctor employment;

1.3 Republic of Ireland and European Law (“ROI and EU Law”) means the Data Protection Act 1988 as amended by the Data Protection (Amendment) Act 2003 and the Data Protection (Access Modification) (Health) Regulations 1989 and the ePrivacy Regulations 2011 (S.I. 336 of 2011) which gives effect to the EU ePrivacy Directive 2002/58/EC (as amended by Directive 2006/24/EC and 2009/136/EC); and the European Union (Consumer Information, Cancellation And Other Rights) Regulations 2013 (Si 484/2013), (Distance Selling Regulations); and

1.4 “Apps and Websites” means the Application (IOS or Android) or Website, including Mobile Website that you are currently using including www.vhionlinedoctor.ie and any sub-domains of these websites unless expressly excluded by their own terms and conditions.

Scope of this Policy
2.1 This Policy applies only to the actions of VideoDoc and Users with respect to this App and Website. It does not extend to any Applications (IOS or Android) or websites that can be accessed from this App and Website including, but not limited to, any links we may provide to social media websites.

Data Collected
3.1 Without limitation, any of the following data may be collected and it may be stored by VideoDoc from time to time:

3.1.1 Contact and demographic information such as name, email address and telephone numbers, address, Eurocode, data of birth, gender, location, preferences and interests; and

3.1.2 Sensitive personal information (Personal Profile and Personal Health Record) including your, state of health, ailments, allergies, diseases or disabilities, medications, physical and mental characteristics, past medical records, photographs, race, gender, age, sexual preferences, family information, details of past consultations; care providers including your GP and nominated Pharmacy, health insurer and policy details; and

3.1.3 Professional and personal information which may or may not be sensitive including your employment status, job or profession, employer, qualifications, specialisations, insurance and medical indemnity information, skills and experience, interests, photographs; and

3.1.4 Technical information including your internet connection details from your mobile phone or other device, your mobile device’s unique ID, the App and Website IP address; mobile or web browser type and version, time zone setting, operating system type and version, login information, and your location; while using the App and Website.

3.2. When you first register with us to access Our products and services using the App and Website you are asked to provide your name, email address, password, date of birth, gender, country of location, Eircode or similar, and telephone contact details.

Location
4.1 When you visit the mobile Application (IOS or Android) and Website, we may use GPS technology (or other similar technology) to determine your current location to determine the city you are located within. We will not share your current location with other users. If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application.

Storage of Data
5.1 We store and process all data on secure servers located in the Republic of Ireland. We do not store your Personal Health Information on your mobile device.

5.2 We do not store any credit or debit card information on Our servers. 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.

Our Retention and Use of Data
6.1 Unless we are obliged or permitted by law to do so, and subject to Clauses 6, your data will not be disclosed to third parties other than under Clauses 6.2 to 6.5. Third Parties do not include other companies within Our VideoDoc Group which may be part of your treatment or developing new services for your care.

6.2 VideoDoc may share data which includes sensitive personal information and medical information obtained during a consultation for purposes of your treatment and ongoing health care with your Carers including your primary GP, nominated pharmacy or, if required, any family or persons involved in your care unless you specifically request that it is not shared.

6.3 By accepting this Privacy Policy and/or Our Terms and Conditions you authorise the Doctor you will see and VideoDoc to use and release the treatment information (“sensitive information”) obtained during this consultation and held by VideoDoc for purposes of your treatment, payment, and ongoing health care. You consent that this release includes your primary GP, nominated pharmacy and any family or persons involved in your care. We will only release the minimum information necessary to. your health insurer in order to assist with reimbursement If you do not wish us to release this information, please notify the General Practitioner. In the Republic of Ireland, the requirement to inform your primary care doctor of your telemedicine consultation is set out in the Guide to Professional Conduct and Ethics for Registered Medical Practitioners, 8th Edition 2016.

6.4 VideoDoc may also release or share your data to make necessary disclosures as required by or in compliance with reasonable requests by regulatory and licensing bodies but only where it is necessary and reasonable to comply with their requests including; the HSE or similar, Irish Medical Council or similar, or as otherwise required by law or regulation. VideoDoc will endeavour to protect your privacy at all times from these requests.

6.5 We may disclose your data if we are under a duty to disclose or share or required to comply with any legal obligation, or to enforce or apply any of Our Terms and Condition and Policies. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. We may disclose or share your data to protect the rights, property, or safety of VideoDoc and its treatment providers (IMC registered General Practitioners, customers, insurers or others).

6.6 All personal data is stored securely in accordance with the principles of the Data Protection Act 1988 as amended by the Data Protection (Amendment) Act 2003.

6.7 For more details on security see Clause 12 below.

6.8 Any or all the above data may be required by us from time to time to provide you with the best possible service and experience when using Our App and website. Specifically, data may be used by us for the following reasons:

6.8.1 To provide Our products and services including those from Our group companies, business partners, suppliers and sub-contractors and Our treatment providers;

6.8.2 Review and improve the quality of your experience of Our products and services, including monitoring compliance with clinical care standards, training and sharing best practice; and

6.8.3 Share necessary information with other treatment providers (including IMC registered General Practitioners,), pharmacists, and suppliers or subcontractors employed in the provision of those products and services; and

6.8.4 Share necessary data with your insurance company, employer or other health care provider where you have requested or otherwise consented to enable them to perform their responsibilities; and

6.8.5 Process payments and detect fraud; and

6.8.6 Make disclosures under Clauses 6.4. and 6.5; and

6.8.7 Communicate with you including transmission by App and Website Alerts, texts and similar messages, email and post to provide Our products and services; and

6.8.8 Distribute transactional, informational and promotional material including communication via market research using email, text, alert, post or other forms of distribution.

Third-Party Websites and Services
7.1 Our App and Website can contain links to other independent Apps or third-party websites, which are not under Our control. This Policy does not extend to your use of such Apps and Websites. Users are advised to read the privacy policy and terms and conditions of other Apps or websites prior to using them.

7.2 VideoDoc may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment processing, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services do not have access to Sensitive Personal data provided by Users of this Website.

7.3 Any data used by such parties is used only to the extent required by them to perform the services that VideoDoc requests. Any use for other purposes is strictly prohibited. Furthermore, any data that is processed by third parties shall be processed within the terms of this Policy and in accordance with the Data Protection Act 1988 as amended by the Data Protection (Amendment) Act 2003.

Changes of Business Ownership and Control
8.1 VideoDoc may from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of VideoDoc. data provided by Users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the data for the purposes for which it was originally supplied to us.

8.2 If any data submitted by Users is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

Controlling Use of Your Data
9.1 Wherever you are required to submit data, you will be given options to restrict Our use of that data. This may include the use of data for direct marketing purposes and sharing data with third parties.

Your Right to Withhold Information
10.1 You may access certain areas of the App or Website without providing any data at all. However, to use all features and functions available on the App or Website you may be required to submit certain data.

10.2 You may restrict your Internet browser’s use of Cookies. For more information, see Clause 13.

Accessing your own Data
You have the right to ask for a copy of any of your personal data held by VideoDoc (where such data is held) on payment of a small fee which will not exceed the applicable Statutory Fee as laid down in the ROI as appropriate. If the data is held in more than one location a single fee shall apply.

Security
Data security is of great importance to VideoDoc and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected via this App and Website.

Cookies
13.1 This Website may place and access certain first party Cookies on your computer. First party cookies are those placed directly by VideoDoc via this Website and are used only by VideoDoc. Use Cookies to improve your experience of using the Website and to improve Our range of products and services. VideoDoc has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected always. Any First party cookies currently used on this Website as at the date of these Terms and Conditions are set out below.

13.2 All Cookies used by this Website are used in accordance with current ROI and EU Cookie Law as applicable.

13.3 Before any Cookies are placed on your computer, subject to sub-Clause 13.5, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling VideoDoc to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

13.4 Certain features of the Website depend upon Cookies to function. ROI and EU Cookie Law deem these Cookies to be “strictly necessary”. The strictly necessary cookies currently used on this site as at the date of these Terms and Conditions are set out below.

13.5 You can choose to enable or disable Cookies in your Internet browser. Most Internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most Internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your Internet browser.

13.6 You can choose to delete Cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

13.7 It is recommended that you ensure that your Internet browser is up-to-date and that you consult the help and guidance provided by the developer of your Internet browser if you are unsure about adjusting your privacy settings.

Marketing Material and Your Rights to Opt-Out
14.1 If you no longer wish to receive informational or promotional material from us by Alerts, texts and similar messages, email and post please contact us at Vhi Online Doctor, VideoDoc Limited, 8 The Mall, Beacon Court, Sandyford, Dublin, D18 C2D0, Ireland. Alternatively, you may email us at info@vhionlinedoctor.ie

Your Rights
15.1 You can stop all collection of information by the App and Website easily by uninstalling the Application or ceasing to use the App and Website. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network to remove the App and Website.

15.2 We are required by best practice and certain laws to hold information, including sensitive information about you such as personal information, details of past consultations and medical health records (“sensitive personal information”). We only hold information in line with applicable laws and best practice to the extent it is absolutely necessary to provide Our products and services to you and to develop our business and services. You confirm that VideoDoc may hold your information for use as Anonymised Data in the improvement of its Services and in the development of its business including with Vhi and third parties. In this context, Anonymised Data refers to data from which you cannot be identified.

Changes
16.1 VideoDoc will attempt to keep the information and the resources contained on or accessible through its Apps and Websites timely and accurate, but makes no guarantees, and disclaims any implied warranty or representation, about its accuracy, relevance, timeliness, completeness, or appropriateness for a particular purpose.

16.2 VideoDoc may change or modify the information, services and any other resources contained on or accessible through its Apps and Websites, or discontinue its Apps and Websites altogether, at any time without notice. Accordingly, you agree to review this agreement periodically, and your continued use of these Apps and Websites shall be deemed your acceptance of the modified agreement.

16.3 VideoDoc reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the App and Website and you are deemed to have accepted the terms of the Policy on your first use of the App and Website following the changes.

Version
This Privacy Policy and the relationship between you and VideoDoc Limited are dated 3rd January, 2017 and should be construed in conjunction with Our Terms and Conditions and Medical Consent Policies dated 3rd January, 2017.

Contact
We want to improve Our products and services through your feedback. If you have any enquiries, questions, comments or even complaints please feel free to contact us at Vhi Online Doctor, VideoDoc Limited, 8 The Mall, Beacon Court, Sandyford, Dublin 18, D18 C2D0, Contact number: 01 9073400. Email: info@vhionlinedoctor.ie

©VideoDoc Limited, 3rd January, 2017

Get in

touch

If you have any questions,

give us a call on  01 9073400
Email info@vhionlinedoctor.ie