This Privacy Notice and its Addendum(s) (“Privacy Notice”) delineate the procedures by which Medtracker, its respective subsidiaries, affiliates, associated companies, and jointly controlled entities (collectively “Medtracker,” “we,” “us,” or “our”) collect, utilize, process, and disclose Personal Data via the utilization of Medtracker’s mobile applications and websites (“Apps” and “Websites,” respectively), as well as other globally-operated products, features, and services under the purview of Medtracker (collectively referred to as “Services”).
This Notice is applicable to consumers, agents, vendors, suppliers, partners (including driver, delivery, and merchant partners), contractors, and service providers (collectively referred to as “you” or “yours”).
“Personal Data” encompasses information capable of identifying an individual or from which an individual is identifiable. This includes, but is not limited to, name, nationality, telephone number, bank and credit card details, personal interests, email address, image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information, and financial information.
We adhere to collecting, using, disclosing, or processing Personal Data in accordance with this Privacy Notice based on your consent, or in adherence to applicable laws, such as when:
– Required to comply with legal obligations.
– Necessary to enter into or execute a contract with you.
– Pursuant to our legitimate interests or the legitimate interests of any other individuals, including purposes outlined in this Privacy Notice.
I. COLLECTION OF PERSONAL DATA
We collect Personal Data through various means, including:
1. You provide Personal Data to us:
– When completing user profiles or registration forms.
– To assess eligibility for services as a Medtracker partner.
– Interaction with social media pages.
– Participation in contests or events organized by us.
– Verification of identity through various means.
– Completion of demographic information in surveys.
– Agreement to in-vehicle audio and/or video recording features.
2. When our services are used:
– Collection through the normal operation or use of our Apps, Websites, and Services.
– In-vehicle audio and/or video recording applications or devices.
3. Personal in-vehicle applications or devices:
– Installation for safety and security purposes.
4. From other sources:
– Referral programs.
– Business partners, insurance, and financial providers.
– Publicly available or governmental sources.
– When users add you as an emergency contact or recipient of services.
– Marketing services providers or partners.
Sensitive Personal Data is collected with consent and in strict compliance with applicable laws. If Personal Data of other individuals is provided, it is assumed that necessary consent has been obtained.
II. USE OF PERSONAL DATA
Medtracker may use Personal Data for purposes such as providing services and features, safety and security, user support, research and development, legal purposes, marketing, and promotions, and user-published content.
III. DISCLOSURE OF PERSONAL DATA
Personal Data may be shared with other users, third parties, administrators of Medtracker accounts, subsidiaries and affiliates, service providers, business partners, legal advisors, governmental authorities, and in business transfers.
IV. RETENTION OF PERSONAL DATA
Personal Data is retained for the necessary period to fulfill the outlined purposes, and steps are taken to erase, destroy, anonymize, or prevent access or use when no longer necessary.
V. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Transfers of Personal Data to other countries are done in compliance with legal obligations, with lawful bases and appropriate safeguards in place to ensure protection.
VI. COOKIES, RELATED TECHNOLOGIES, AND ADVERTISING
Medtracker utilizes Cookies for various purposes, including essential functions, authentication, advertising measurement, site traffic analysis, and personalized user experience. Users have the right to disable cookies, and settings can be adjusted through internet browser configurations.
VII. PROTECTION OF PERSONAL DATA
Reasonable legal, organizational, and technical measures are implemented to protect Personal Data. Access to Personal Data is restricted to employees on a need-to-know basis.
VIII. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
Users may inquire about, correct, delete, restrict or object to the processing of Personal Data, withdraw consent, request data portability, and lodge complaints with relevant authorities.
IX. AMENDMENTS AND UPDATES
Medtracker reserves the right to modify, update, or amend this Privacy Notice, with notifications provided at least five business days before the effective date. Continued use of the Apps, Websites, or Services constitutes acceptance of such amendments.
X. CONTACT US
If you have any questions, complaints, concerns, or comments about our Privacy Policy, we welcome you to contact us through the following details:
Company Name: Medtracker
Contact Number: 0927 677 3688
Email Address: medtracker.ph@gmail.com
Location: Davao, Philippines
Website: medtrackerph.com
Attention: Personal Data Protection Officer
You also have a right to file a complaint with the relevant authorities if you believe your privacy rights have been violated.
ADDENDUM 1: MEDTRACKER FOR BUSINESS
I. INTERPRETATION
All capitalized terms but undefined terms used herein shall bear the same meaning as those defined in the Terms of Use and Medtracker’s Privacy Notice.
This Addendum forms part of the Medtracker Privacy Notice. In the event of any inconsistency between the MedTracker Privacy Notice and this Addendum, this Addendum shall prevail.
II. MEDTRACKER’S RELATIONSHIP WITH USERS AND CLIENTS
How Medtracker for Business works
MedTracker for Business is provided as an add-on feature for organizations (“Client”) to facilitate billing for its Authorized Users’ (e.g., employees) use of Medtracker’s Services in the course of work.
When a Client chooses to utilize Medtracker for Business, Medtracker will disclose detailed trips, reservations and any necessary information that Authorized Users have tagged as being for business purposes to the Client. Apart from this, Medtracker does not disclose other Personal Data of Authorized Users to the Client.
For ease of reference, Authorized Users and individual users will each be referred to as a “User” and collectively as “Users” in this Addendum.
Medtracker is a data controller, so are our Clients
In respect of any User and the processing of their Personal Data, Medtracker acts as a data controller. For further information on how Medtracker collects, uses, and discloses Users’ Personal Data, please refer to the Medtracker Privacy Notice.
Due to the way Medtracker for Business works, Medtracker does not process any Personal Data for and on behalf of the Client. Accordingly, Medtracker is not the data processor of the Client but an independent data controller in respect of all Personal Data that it processes in the course of providing the Medtracker for Business feature. Likewise, the Client is an independent data controller of the Personal Data that it discloses to and/or receives from Medtracker.
As independent controllers, Medtracker and the Client individually determine the purposes and means of processing Personal Data, subject to the provisions set out in the Terms of Use and this Privacy Notice. Medtracker and the Client are also individually responsible to ensure the protection of Personal Data under their charge.
III. WHAT PERSONAL DATA IS COLLECTED, PROCESSED AND DISCLOSED
What Medtracker collects as part of Medtracker for Business
In order to provide the Medtracker for Business feature, the User or the Client will be required to provide the following information about the User to Medtracker:
– Full name.
– Business email address.
– Other identifying information about the User as reasonably requested by Medtracker.
Medtracker will use this information for the purposes of:
– Authenticating the User.
– Where applicable, linking the Authorized User’s account with the Client’s MedTracker for Business account or tracking the Authorized User’s business profile bookings on the Apps, as the case may be.
– Where applicable, verifying the Billing status of such Authorized User from time to time.
– Contacting the User in accordance with the purposes set out in the Medtracker Privacy Notice.
Upon onboarding a User to the App, Medtracker will process the Personal Data of the User in accordance with the Medtracker Privacy Notice and this Addendum.
What Medtracker discloses to its Clients
Medtracker will disclose transaction information as determined by Medtracker from time to time to the Client to facilitate Corporate Billing.
What Medtracker discloses to its individual user
Depending on the business profile settings selected by the individual user, the user may retrieve and generate reports containing his/her transactions within the app or website.
IV. PARTIES’ OBLIGATIONS
The Client and MedTracker shall each:
– Individually inform their data subjects of how each processes Personal Data and allow their data subjects to exercise their rights under the local data protection/data privacy laws.
– Comply with the obligations applicable to each party under the applicable data protection/data privacy laws when processing any Personal Data of the Proposed or Authorized Users.
– Obtain the necessary consents (if applicable) for its disclosure of Personal Data to facilitate the provision of the Medtracker for Business feature.
– Implement appropriate legal, technical, and organizational measures to protect Personal Data against unauthorized or unlawful processing and against unauthorized loss, destruction, damage, alteration, or disclosure, as well as any breach or attempted breach of its security measures (“Information Security Incident”).
ADDENDUM 2: MEDTRACKER DEFENSE PRIVACY STATEMENT
This Privacy Statement (“Statement”) describes how Medtracker collects, uses, processes, and discloses data through the use of Medtracker Defense and its related services (“Medtracker Defense”).
Medtracker provides its customers (“MD Customers”) with the Medtracker Defense service that helps to prevent, detect, and combat fraud or unsafe activities on their platforms and applications (such as web-based and mobile applications based e-commerce platforms) (“Digital Platforms”). MD Customers will integrate Medtracker Defense into their Digital Platforms to identify potentially fraudulent activities on their Digital Platforms.
This Statement applies to the users of MD Customers’ Digital Platforms (“you”), and strictly relates to the data collected, used, and disclosed on behalf of MD Customers for the purposes of providing Medtracker Defense. Kindly refer to the applicable terms of service and/or privacy notices of the MD Customers to understand how they otherwise collect, use, and disclose your data.
I. COLLECTION OF DATA
To provide Medtracker Defense to MD Customers, information from your device and information relating to your use of MD Customers’ Digital Platform will be collected from MD Customers. Such information includes device identifier information (such as IMEI, Android ID, MAC address, etc.), device and hardware information (such as device name, screen size, etc.), account information (such as email address, phone number, etc.) as well as other contextual data in relation to your use of MD Customers’ Digital Platforms (such as IP address, Wifi address, GPS location data, address, payment details, etc.). Such information is collected by MD Customers when you interact with MD Customers’ Digital platforms, in accordance with MD Customers’ terms of service and/or privacy notices.
We may combine the information we have collected from MD Customers with data points from Medtracker’s ecosystem to derive relevant insights (for example, insights on whether there are signs of app modification, data manipulation, device tampering, GPS spoofing). We do not attempt to personally identify you based on the information above to provide Medtracker Defense to MD Customers.
II. USE OF DATA
We generally process your information on behalf of MD Customers in order to assist with their fraud detection efforts. It is up to the MD Customers’ sole discretion to apply the outcome derived from the use of Medtracker Defense on their Digital Platforms.
In this regard, we may use, combine, and process your information for the following purposes (“Purposes”):
– Providing, operating, and maintaining Medtracker Defense.
– Investigating faults with, and troubleshooting, Medtracker Defense.
– Research and development for Medtracker Defense, including but not limited to improving existing features and services, or developing new features and services, for Medtracker Defense.
– Detecting patterns in the datasets
collected to gather insights on fraudulent activities.
– Regulatory and internal audit compliance purposes.
– Responding to any law enforcement request or court order.
Please be assured that the information collected will not be used by Medtracker for any marketing efforts or combined with any other datasets available to Medtracker in a manner that unfairly prejudices you.
III. DISCLOSURE OF DATA
We may need to share information with various parties for the Purposes. These parties include:
– MD Customers, with whom you are registered as a user.
– Our subsidiaries and affiliates.
– Our service providers (for example, we use Amazon Web Services’ cloud to host your information).
– Our legal advisors, law enforcement officials, and government authorities.
Save for the above mentioned parties, we will not disclose your information to any other third party.
IV. YOUR RIGHTS OVER YOUR DATA
In accordance with applicable privacy laws and to the extent that any information collected pursuant to the use of Medtracker Defense may constitute personal data, you may be entitled to access or update your personal data. Given that Medtracker Defense’s processing of your personal data is premised on MD Customers’ use of Medtracker Defense when you use their Digital Platforms, if you would like to exercise your rights, we recommend that you directly approach the operator of the Digital Platform you are using to obtain more information about how your information is used and processed, and to exercise your rights over your personal data.
V. RETENTION OF DATA
We retain your information for as long as we have a business purpose (i.e., to provide Medtracker Defense, and to fulfill the Purposes) or legal purpose to do so. Once these purposes are satisfied, we take steps to destroy or anonymize your information.
VI. INTERNATIONAL TRANSFERS OF DATA
Your information may be transferred from the country, state, and city (“Home Country”) in which you are present while using MD Customers’ Digital Platforms to another country, state, and city (“Alternate Country”).
VII. PROTECTION OF DATA
We will take reasonable legal, organizational, and technical measures to ensure that your information is protected. This includes measures to prevent data from getting lost or used or accessed in an unauthorized way. We limit access to your information to our employees on a need-to-know basis. Those processing your data will only do so in an authorized manner and are required to treat your information with confidentiality.
Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted through any online means; therefore, any transmission remains at your own risk.
VIII. AMENDMENTS AND UPDATES
Medtracker shall have the right to modify, update, or amend the terms of this Statement at any time by placing the updated Statement on its website.
If you have any queries about how your data is being used, please reach out to the MD Customer with whom you may be registered as a user. If you have other queries relating to Medtracker Defense, please contact our Data Privacy Officer via the form set out in Medtracker’s Privacy Notice
IX. PROMINENT DISCLOSURE
This app, Medtracker, collects location data to enable delivery and navigation features, even when the app is closed or not in use.
X. CONTACT US
For inquiries regarding this Privacy Notice or out data practice, to exercise your rights under applicable data protection laws, or for any other privacy-related inquiries, please contact us at:
Email: medtracker.ph@gmail.com