“Customer” means an individual who (a) has contacted us through any means (such as through any of the Platforms) in relation to the goods or services available on the Platforms, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
WHAT INFORMATIONS ARE COLLECTED FROM YOU
2. Depending on the nature of your interaction with us, some examples of personal data that we may collect from you include
(a) Your name, identification numbers such as NRC, Passport Number, FIN, residential address, email address, telephone number, nationality, gender and date of birth;
(b) Medical records and history
(c) Billing information that you provide us (e.g. credit card or online payment system account information);
(d) Information about the computer or mobile device you are using; or
(e) Other information which you may input into the platforms or related services.
3. We may also seek permission to use the camera, microphone, and phonebook/contact data at points where required.
4. We may also collect information other than Personal Information from you through the Website when You visit and /or use the Website. Such information may not personally assist us to identify you and will be stored in server logs. Such Non-Personal Information may include
(a) Your usage details such as time, frequency, duration and pattern of use, features used, and the amount of storage used,
(b) Master and transaction data and other data stored in Your user account,
(c) Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system and other visitor details collected in our log files.
HOW WE COLLECT YOUR INFORMATION
4. We may collect your information by the following means but are not limited to those.
(a) When You register on Our Website,
(b) When You create a profile on Our Website or as part of Services such as mobile application
(c) When You provide Your Information to us,
(d) When You use the features on Our Website and/or when You use Services,
(e) When You access Website or Services,
We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).
5. As you use the Platforms, services, or purchase or arrange for the delivery of products, certain information may be passively collected:
(a) Site Activity Information: We may keep track of some of the actions you take on the Platforms, such as the content of searches you perform on the Platforms;
(b) Access Device and Browser Information: When you access the Website from a computer or other device, we may collect anonymous information from that device, such as your Internet protocol address, browser type, connection speed and access times;
(c) Cookies (i.e. small pieces of information that a site sends to your browser while you are viewing a website): We may use both session Cookies (which expire once you close your web browser) and persistent Cookies to make the Platforms and services easier to use, to make our advertising better, and to protect both you and MyanCare. You can instruct your browser, by changing its options, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. If you do not accept Cookies, however, you will not be able to stay logged in to the Platforms. We presently do not honor “Do Not Track” requests across all parts of our Platforms.
(d) Real-Time Location: Certain features of the Platforms use GPS technology to collect real-time information about the location of your device so that the Platforms can connect you to a healthcare professional/treatment provider near your location.
(e) Device information: We may also collect non-personal information from your mobile device or computer. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the application(s) and information about the type of device or computer you use. Besides, in the event, our application(s) crashes on your mobile device we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s).
HOW THE INFORMATION COLLECTED IS USED
6. We may collect and use your personal data for any or all of the following purposes:
(a) To enable you to use the Website and utilize the Services. For instance, you may provide your health-related information on the website in order to consult privately with a doctor, or you may provide your financial information to process a payment that you need to make on the website.
(b) verifying your identity;
(c) responding your inquiries;
(d) managing your relationship with us;
(e) processing or facilitating the processing of your claims;
(f) processing payment or credit transactions;
(h) for proper administration of website and our services;
(i) notifying you when Platform updates are available;
(j) marketing and promoting the Platforms, and the services and products offered on the Platforms to you;
(k) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(l) for analysis of our products and services for better presentation or outcome;
(m) any other purposes for which you have provided the information;
(n) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Myanmar or abroad, for the aforementioned purposes; and
(o) any other incidental business purposes related to or in connection with the above.
7. We may disclose your personal data where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you:
(a) To our subsidiaries, related companies, affiliates, or partners;
(b) To the relevant parties who may process your claims for your medical care. For the avoidance of doubt, we will not disclose any confidential medical diagnoses to such parties unless your consent is provided to us separately in writing;
(c) To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them (including logistics service providers, data service providers);
(d) As required by law, which can include providing information as required by a court order;
(e) When we believe in good faith that disclosure is necessary to protect your safety or the safety of others, to protect our rights, to investigate fraud, or to respond to a government request;
(f) To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of MyanCare ’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data maintained on the Platforms is among the assets transferred;
(g) To any other person or organization disclosed by us when you provide the information.
8. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract should you be hired) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
WITHDRAWING YOUR CONSENT
10. The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing or via email to our office whose contact is provided below.
11. Upon receipt of your written request to withdraw your consent, we may require a reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
12. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request.
13. Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws. For the avoidance of doubt, such withdrawal of consent shall not require us to delete any personal data that has already been collected by us from our records.
ACCESS TO AND CORRECTION OF PERSONAL DATA
14. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. Such a request shall include the details of the requestor, description of the personal data being requested, and the date and time range the personal data was believed to be collected.
PROTECTION OF PERSONAL DATA
15. To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures such as up-to-date antivirus protection, encryption, and disclosing personal data both internally and to our authorized third-party service providers and agents only on a need-to-know basis.
16. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
RETENTION OF PERSONAL DATA
17. We may allow you to delete some of the records that are stored on the Application by clicking “History” > “Delete”. Such deletion shall only delete your records from the Application but a back-up copy shall be retained in accordance with clauses 21 and 22 below.
18. We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.
19. We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF MYANMAR
20. We generally do not transfer your personal data to countries outside of Myanmar. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the LAW PROTECTING THE PRIVACY AND SECURITY OF CITIZENS.
21. You may contact our office, if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Email Address: firstname.lastname@example.org