CLEARLINE HMO Privacy Notice

Overview

We appreciate your trust in us. Committed as we are to ensuring that we maintain the level of trust in us, we believe it is our responsibility to help you understand our privacy practice.

This Privacy Policy and Data Protection Notice ("Notice") outlines how Clearline HMO ("we," "us," or "our") collects, uses, discloses, and protects personal data of individuals ("you" or "data subjects") in accordance with applicable data protection laws. This Notice also explains your right to access your personal data and how you can exercise this right. Please read this Notice carefully to understand our practices regarding your personal data.

Data Collection

We collect User ("Enrollees", "Provider" and "Customer") data via a couple of mediums. Only what we need is collected and processed with the aim of providing the best possible service to our Users.

Data collected is provided:

• During account creation by the User.
• During the usage of our software application (the "Clearline HMO App").

We collect data such as:

• Contact details: Information such as name, phone number, address, and e-mail address.
• Legal Documents: For verification purposes of our Providers, we require documents such as registered corporate records and any related industry regulatory licenses.
• Payment Information: Details such as bank account numbers are collected to facilitate payment to our Users.
• Communication records: Information such as correspondence while engaging with our support teams or customer service agents via our different mediums.
• Data relating to transaction activities: This includes information such as claims and refunds.

Processing the Data

We process collected data in view of providing our Users with a smooth, seamless, and efficient experience. We may use the information provided to us to perform any of the following:

• Create and manage your account.
• Provide you with targeted advertising and information about current promotions.
• Provide E-mail reports on your health-related activities.
• Develop analytical reports for internal and external purposes.
• Provide updates on our products and services.
• Monitor and analyze trends and activities to enhance our value proposition.
• Process financial transactions.
• Respond to product and service requests.
• Continuously improve our application.
• Enhance the safety and security of our Users and services.
• To provide support to our Users.
• For legal proceedings.
• Perform other business activities as needed.

Data Retention

We retain User data for the purposes above for as long as necessary. We retain different categories of data for different periods of time depending on the type of data and the purpose for which it was collected.

For ease of understanding, we have broken down the categories below:

• Personal Information: Personal data such as personal information and credentials will be stored for as long as the User has an active account. Once activity ceases, the User’s data will be maintained for a period of six (6) years after the policy renewal date.
• Client Profile Data:Request history data will be stored for six (6) years , after which the data will be anonymized.
• Event of Fraud: If there are suspicions of a criminal offence, fraud or false information having been provided, the User data will be stored as long as necessary according to the internal, legal, and regulatory requirements.
• Data Deletion: Users may request the deletion of their accounts at any time. Clearline HMO may however retain User data even after a deletion request due to legal or regulatory requirements or for reasons stated in this policy. Please note that uninstalling the Clearline HMO App in your device does not automatically result in the deletion of your personal data.

To delete your data, please follow the steps below:

• For cooperate clients: Kindly reach out to our company HR assistance with deletion or erasure of your personal data, please Send an email to dpo@ClearlineHMO.com.

Lawful Basis

We understand the importance of ensuring that User data is handled in a lawful and transparent manner. We are allowed to use personal information in the ways described in the previous sections if we have a proper reason to do so.

Personal data is generally processed in order to fulfill our contractual agreement with you. This means that to give you the service we promised and meet our terms and conditions, we’ll process your personal data.

Legitimate interests: In some circumstances, we process personal data by relying on legitimate interest grounds. Legitimate interests include our commercial interests in providing an innovative, personalized, safe, and profitable service to our Users unless those interests are overridden by other interests. Our legitimate interests also include things like investigating and detecting fraudulent payments and other malicious activities, maintaining the security of our network and systems, and responding to suspected or actual criminal acts.

Alternative legal bases: We may also rely on alternative legal basis to process personal data. Such occasion could be when we need to comply with a legal obligation such as for processing data when the law requires it, including, for example, cases of fraud; if there is a valid legal request to disclose personal information to a third-party such as a Court or regulatory authority; to protect your vital interest or those of others in the event of an emergency.

If you choose not to give us personal information, it may prevent us from fulfilling the contract with you or stop us from doing something expected of us by law. It may also mean that we cannot operate and manage your account effectively.

Links to Third-Party Sites

Our Services may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by other websites or other services. You should exercise caution when accessing such websites and review the privacy statements applicable to the third-party websites and services you use.

Advertising and Analytics Services Provided by Others

We and third parties that provide content or functionality on the Services or provide us analytics and advertising services may collect or receive information about your use of the Services and other websites or mobile applications, including through the use of cookies, web beacons, and similar technologies. This information may include, for example, your IP address, browser, device information, pages viewed, time spent on pages, links clicked, and conversion information.

This information may be combined with information collected across different websites, online services, and linked or associated devices to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your online activity.

For more information about Internet-based ads, or to opt out of receiving targeted advertising from participating companies, please visit www.aboutads.info/choices.

Data Subject Rights

We provide Users with the ability to stay in control of their personal data. Users may update, request for their data, and generally control how we handle their personal data.

• Right to access personal Information: Users can request copies of their personal data.
• Right to change or update personal information: Users may request change or update of their personal data at any time by reaching out to the DPO.
• Right to restrict processing of data: Users may object or restrict processing of their personal data in certain circumstances. There may however be some exceptions to this request in instances touching on legal matters.
• Right to data portability: Users have the right to request transfer of their personal information from one organization to another.
• Right to erasure: Users have the right to request erasure of personal information at any time.

Users may submit requests or questions to the Data Protection Officer (DPO) using the contact details provided at the end of this document.

Sharing and Disclosure of Data

We may share your personal information with third-party affiliates or subsidiaries. We warrant that we would only share your personal data with third parties for connected purposes and only if we have a lawful basis to do so.

If at any time during your use of the Service we discover that we do not have a lawful basis for sharing any of your Personal Data, then we shall cease sharing your data and notify any such third-party affiliate or subsidiary immediately to cease Processing your Personal Data.

Data Subject Request

Users may submit a data subject request by contacting our data protection officer for questions, concerns, or when they wish to exercise their right to access personal data via the details below:

Do-Not-Track Signals

Some web browsers may transmit "do-not-track" signals to the websites and other online services with which the browser communicates. There is no standard that governs what, if anything, websites and online services should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard for responding is established, we may revisit our policy on responding to these signals.

Change to this Notice

We may update this notice from time to time to reflect changes in our data practices or legal obligations. The updated Notice will be posted on our website, and we encourage you to review it periodically for the latest information on our privacy practices.