INTRODUCTION

This privacy notice tells you about the information we process about you whilst you are using the SmartAccess platform. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data as well as about the rights you have over your data.

Who we are

Smart Applications International is a leading ICT solutions provider delivering a wide range of world class technological solutions in Kenya.

Fondly known as Smart within the industry, the company was founded to provide innovative, secure and high-tech solution in Africa and beyond. Staying ahead through constant research and innovation.

We offer solutions that are secure, relevant and convenient.

Our Data Protection Officer can be contacted via email: dpo@smartapplicationsgroup.com

Personal data

Under the Kenya Data Protection Act (KDPA) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

What personal data we collect

We collect and process the following types of information from you:

• Information that you provide while signing up on the platform. This includes information provided via email, mobile application, and/or by any other method.
• In particular, We process personal details such as name, email address, National ID number, finger print data, telephone number, member number, date of birth, next of kin, covered dependents, gender, diagnosis, medication information.
• If you contact us through our call center, we may keep a record of that correspondence.

How We use the personal data we collect about you

We rely on your consent in processing your personal data during the onboarding process and for keeping records of the process. Processing your data allows us to manage your medical cover so as to deliver world class convenience to you

Where you have provided consent to use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use.

Who we disclose your personal data to

We do not disclose, sell or otherwise distribute your personal data to any third party. Smart Applications acts to protect your personal data and ensure that unauthorized individuals do not have access to your Information by using security measures to protect personal data.

How we protect your personal data

We take appropriate measures to ensure that your personal data is kept secure including security measures to prevent personal data from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information inorder to grant you access to care will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and the authority of a suspected data security breach where we are legally required to do so.

How long we keep your personal data

When you sign up to the SmartAccess platform, we keep your data for as long as you are active on our platform.

Should you wish to withdraw your consent, your data is deleted or destroyed.

Your rights as a data subject

Under the KDPA, you have a number of important rights. In summary, they include rights to

• Require us to correct any mistakes in your information which we hold
• Require the erasure of personal data concerning you in certain situations
• Receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another organization in certain situations
• Object in certain other situations to our continued processing of your personal data
• Otherwise restrict our processing of your personal data in certain circumstances
• Claim compensation for damages caused by our breach of any data protection laws.

If you wish to exercise any of the rights explained above, please contact the Data Protection Officer on dpo@smartapplicationsgroup.com

Update to this privacy notice

We, Smart Applications International respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our mobile application (“GetSmart”).

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the application.

Smart Applications reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application or make payments, including any in-game virtual items, which may also collect and use data about you. Smart Applications is not responsible for any of the data collected by any such third party.

1. Access to the Mobile Application and use of the Services offered on the Mobile Application by Smart Applications Limited and/or its group of companies is subject to this Privacy Policy. By accessing the Mobile Application and by continuing to use the Services offered, you are deemed to have accepted this Privacy Policy, and in particular, you are deemed to have consented to our use and disclosure of your personal information in the manner prescribed in this Privacy Policy and for the purposes set out in Clauses in this terms and conditions We reserve the right to amend this Privacy Policy from time to time. If you disagree with any part of this Privacy Policy, you must immediately discontinue your access to the Mobile Application and your use of the Services.

2. As part of the normal operation of our Services, we collect, use and, in some cases, disclose information about you to third parties. Accordingly, we have developed this Privacy Policy in order for you to understand how we collect, use, communicate and disclose and make use of your personal information when you use the Services on the Mobile Application: –

(a) Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.

(b) We will collect and use of personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.

(c) We will only retain personal information as long as necessary for the fulfillment of those purposes.

(d) We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.

(e) Personal information should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

(f) We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

Smart Applications International Limited,

International House, 11th floor

P.O. Box 57776, Nairobi – 00200

Tel: +254 20 320 6000 Cell: +254 718 222 000

Toll Free 0800723600

info@smartapplicationsgroup.com