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What is personal information?
- This privacy policy (“Privacy Policy”) applies to your use of the domain name
www.mecuresmartbuy.com, an internet based
portal, and Me Cure SmartBuy, a mobile application, owned and operated by Me Cure
Smartbuy Nigeria Limited, a company
duly incorporated under the provisions of the _____________ (hereinafter, referred to as
“MSB” or “We” or “Our” or “Us”
or “Company”). The domain name and the mobile application are collectively referred to
as “Website”.
- The Website is a platform that facilitates the purchase of pharmaceutical products for
sale by various relevant
pharmacies (hereinafter referred to as “Services”, with the relevant pharmacies referred
to as “Sellers”). The
arrangement between the Sellers and MSB shall be governed in accordance with this
Privacy Policy and the Terms of Use.
The Services would be made available to such natural persons who have agreed to become
buyers on the Website after
obtaining due registration, in accordance with the procedure as determined by MSB, from
time to time (referred to as
“You” or “Your” or “Yourself” or “User”, which terms shall also include natural persons
who are accessing the Website
wmerely as visitors). The Services are offered to the Users through various modes which
shall include issue of discount
coupons and vouchers that can be redeemed for various goods/ services offered for sale
by the Sellers.
- We have implemented reasonable security practices and procedures that are commensurate
with the information assets being
protected and with the nature of our business. While we try our best to provide security
that is commensurate with the
industry standards, because of the inherent vulnerabilities of the internet, we cannot
ensure or warrant complete
security of all information that is being transmitted to us by you.
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For the purpose of providing the Services and for other purposes identified in
this
Privacy Policy, MSB will be required
to collect and host certain data and information of the Users. MSB is committed to
protecting the Personal Information
of the Users and takes all reasonable precautions for maintaining confidentiality of
the
User’s Personal Information.
This Privacy Policy has been designed and developed to help you understand the
following:
- The type of Personal Information (including Sensitive Personal Data or
Information) that MSB collects from the Users
- The purpose of collection, means and modes of usage of such Personal Information
by MSB
- How and to whom MSB will disclose such information
- How MSB will protect the Personal Information including Sensitive Personal Data
or Information that is collected from
the Users
- How Users may access and/ or modify their Personal Information.
- This Privacy Policy shall apply to the use of the Website by all Users / Sellers.
Accordingly, a condition of each
User's use of and access to the Website and to the other services provided by MSB to
Users is their acceptance of this
Privacy policy. Any User is required to read and understand the provisions set out
herein prior to submitting any
Sensitive Personal Data or Information to MSB, failing which they are required to leave
the Website immediately.
- This Privacy Policy is published in compliance of the (Nigeria) Information Technology
Act, 2000 and the rules,
regulations, guidelines and clarifications framed thereunder, including the (Nigeria)
Information Technology (Reasonable
Security Practices and Procedures and Sensitive Personal Data or Information) Rules,
2011.
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What is personal information?
- “Personal Information” means any information that relates to a natural person, which,
either directly or indirectly, in
combination with other information available with MSB, is capable of identifying the
person concerned.
- “Sensitive Personal Data or Information” means Personal Information of any individual
relating to password; financial
information such as bank account or credit card or debit card or other payment
instrument details; physical,
physiological and mental health condition; sexual orientation; medical records and
history; biometric information; any
detail relating to the above as provided to or received by MSB for processing or
storage. However, any data/ information
relating to an individual that is freely available or accessible in public domain or
furnished under the Right to
Information Act, 2005 or any other law shall not qualify as Sensitive Personal Data or
Information.
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Types of personal information collected by MSB:
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A User may have limited access to the Website and utilize some of the Services
provided
by MSB without creating an
account on the Website. Unregistered Users can access some of the information and
details available on the Website. In
order to have access to all the features and benefits on our Website, a User may be
required to first create an account
on our Website. As part of the registration process, MSB may collect the following
categories of Personal Information
from the Users (hereinafter collectively referred to as “User Information”):
- Name
- User ID
- Email address
- Address (including country and ZIP/postal code)
- Gender
- Age
- Phone number
- Password chosen by the User
- Valid financial account information
- Other details as the User may volunteer
- In order to avail the Services, the Users may be required to upload copies of their
prescriptions, on the Website and/
or e-mail the same to MSB in accordance with the Terms of Use and the prescriptions will
be stored/ disclosed by MSB
only in the manner specified in this Privacy Policy and the Terms of Use. The term “User
Information” shall also include
any such prescriptions uploaded or otherwise provided by Users.
- MSB may keep records of telephone calls received and made for making inquiries, orders,
or other purposes for the
purpose of administration of Services.
- Internet use: MSB may also receive and/or hold information about the
User’s browsing history including the URL of the
site that the User visited prior to visiting the website as well as the Internet
Protocol (IP) address of each User's
computer (or the proxy server a User used to access the World Wide Web), User's computer
operating system and type of
web browser the User is using as well as the name of User's ISP. The Website uses
temporary cookies to store certain
data (that is not Sensitive Personal Data or Information) that is used by MSB and its
service providers for the
technical administration of the Website, research and development, and for User
administration.
- The Website may enable User to communicate with other Users or to post information to be
accessed by others, whereupon
other Users may collect such data. MSB hereby expressly disclaims any liability for any
misuse of such information that
is made available by visitors in such a manner.
- MSB does not knowingly collect Personal Information from children.
- MSB may in future include other optional requests for information from the User
including through user surveys in order
to help MSB customize the Website to deliver personalized information to the User and
for other purposes are mentioned
herein. Such information may also be collected in the course of contests conducted by
MSB. Any such additional Personal
Information will also be processed in accordance with this Privacy Policy.
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Purposes for which your information may be used by MSB:
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MSB will retain User Information only to the extent it is necessary to provide
Services
to the Users. The information
which MSB collects from you may be utilized for various business and/or regulatory
purposes including for the following
purposes:
- Registration of the User on the Website
- Processing the User’s orders / requests and provision of Services (including
provision of safe Services)
- Completing transactions with Users effectively and billing for the products/
Services provided
- Technical administration and customization of Website
- Ensuring that the Website content is presented to the Users in an effective
manner
- Delivery of personalized information and target advertisements to the User
- Improvement of Services, features and functionality of the Website
- Research and development and for User administration (including conducting user
surveys)
- Non-personally identifiable information, exclusively owned by MSB may be used in
an aggregated or non-personally
identifiable form for internal research, statistical analysis and business
intelligence purposes including those for the
purposes of determining the number of visitors and transactional details, and
MSB may sell or otherwise transfer such
research, statistical or intelligence data in an aggregated or non-personally
identifiable form to third parties and
affiliates
- Dealing with requests, enquiries, complaints or disputes and other customer care
related activities including those
arising out of the Users’ request of the Services and all other general
administrative and business purposes
- In case of any contests conducted by MSB in which the User participates, the
User Information may be used for prize
fulfillment and other aspects of any contest or similar offering
- Communicate any changes in our Services or this Privacy Policy or the Terms of
Use to the Users
- Verification of identity of Users and perform checks to prevent frauds
- Investigating, enforcing, resolving disputes and applying our Terms of Use and
Privacy Policy, either ourselves or
through third party service providers
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Disclosure and transfer of your Personal Information:
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MSB may need to disclose/ transfer User’s Personal Information to the following
third parties for the purposes mentioned
in this Privacy Policy and the Terms of Use:
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To Sellers and other service providers appointed by MSB for the purpose of
carrying out services on MSB’s behalf under
contract. Generally these contractors do not have any independent right to share
this information, however certain
contractors who provide services on the Website, including the providers of
online communications services, will have
rights to use and disclose the Personal Information collected in connection with
the provision of these services in
accordance with their own privacy policies.
- To our affiliates in Nigeria or in other countries who may use and disclose your
information for the same purposes as
us.
- To government institutions/ authorities to the extent required a) under the
laws, rules, and regulations and/ or under
orders of any relevant judicial or quasi-judicial authority; b) to protect and
defend the rights or property of MSB; c)
to fight fraud and credit risk; d) to enforce MSB’s Terms of Use (to which this
Privacy Policy is also a part) ; or e)
when MSB, in its sole discretion, deems it necessary in order to protect its
rights or the rights of others.
- If otherwise required by an order under any law for the time being in force
including in response to enquiries by
Government agencies for the purpose of verification of identity, or for
prevention, detection, investigation including
cyber incidents, prosecution, and punishment of offences.
- In case of contests conducted by MSB in which the User participates, the
concerned User’s information may be disclosed
to third parties, also be disclosed to third parties to the extent necessary for
prize fulfillment and other aspects of
such contest or similar offering.
- MSB makes all User Information accessible to its employees and data processors only on a
need-to-know basis. All MSB
employees and data processors, who have access to, and are associated with the
processing of User Information, are
obliged to respect its confidentiality.
- Non-personally identifiable information may be disclosed to third party ad servers, ad
agencies, technology vendors and
research firms to serve advertisements to the Users. MSB may also share its aggregate
findings (not specific
information) based on information relating to the User’s internet use to prospective,
investors, strategic partners,
sponsors and others in order to help growth of MSB’s business.
- MSB may also disclose or transfer the User Information, to another third party as part
of reorganization or a sale of
the assets or business of a MSB corporation division or company. Any third party to
which MSB transfers or sells its
assets will have the right to continue to use the Personal Information and/ or other
information that a User provide to
us.
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Retention of the information:
- All the information collected/ stored under this Privacy Policy and Terms of Use is
maintained by MSB in electronic form
on its equipment, and on the equipment of its employees. User Information may also be
converted to physical form from
time to time. Regardless of the manner of storage, MSB will keep all User Information
confidential and will use/
disclose it only the manner specified under the Privacy Policy and Terms of Use.
- Part of the functionality of the Website is assisting the Sellers to maintain and
organize such information to effect
sale and purchase of products. MSB may, therefore, retain and submit all such records to
the appropriate authorities, or
to Sellers who request access to such information.
- The Website is also designed for assisting the Users to access information relating to
pharmaceutical products. MSB may,
therefore, retain and submit all such records to the relevant Users.
- MSB will also ensure that User Information is not kept for a period longer than is
required for the purposes for which
it is collected or as required under any applicable law.
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Security Practices and Procedures:
- MSB adopts reasonable security practices and procedures to include, technical,
operational, managerial and physical
security control measures in order to protect the Personal Information in its possession
from loss, misuse and
unauthorized access, disclosure, alteration and destruction.
- MSB takes adequate steps to ensure that third parties to whom the Users’ Sensitive
Personal Data or Information may be
transferred adopt reasonable level of security practices and procedures to ensure
security of Personal Information.
- You hereby acknowledge that MSB is not responsible for any intercepted information sent
via the internet, and you hereby
release us from any and all claims arising out of or related to the use of intercepted
information in any unauthorized
manner.
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User's rights in relation to their personal information collected by MSB:
- All the information provided to MSB by a User, including Sensitive Personal Data or
Information, is voluntary. User has
the right to withdraw his/ her/ its consent at any time, in accordance with the terms of
this Privacy Policy and the
Terms of Use, but please note that withdrawal of consent will not be retroactive.
- Users can access, modify, correct and delete the Personal Information provided by them
which has been voluntarily given
by the User and collected by MSB in accordance with this Privacy Policy and Terms of
Use. However, if the User updates
his/ her information, MSB may keep a copy of the information which User originally
provided to MSB in its archives for
User documented herein. In case the User seeks to update or correct, his/ her Personal
Information, the User may
exercise these rights by emailing MSB at care@mecuresmartbuy.com and communicate
the change(s) for updating MSB’s
records.
- If a User, as a casual visitor, has inadvertently browsed any other pages of this
Website prior to reading the Privacy
Policy and the Terms of Use, and such User does not agree with the manner in which such
information is obtained, stored
or used, merely quitting this browser application should ordinarily clear all temporary
cookies installed by MSB. All
visitors, however, are encouraged to use the "clear cookies" functionality of their
browsers to ensure such clearing/
deletion, as MSB cannot guarantee, predict or provide for the behavior of the equipment
of all the visitors of the
Website.
- If a User has inadvertently submitted any Personal Information to MSB prior to reading
the Privacy Policy and Terms of
Use, and such User does not agree with the manner in which such information is
collected, stored or used, then such User
can ask MSB, by sending an email to care@mecuresmartbuy.com containing the rectification
required, whether MSB is
keeping Personal Information about such User, and every User is also entitled to require
MSB to delete and destroy all
such information relating to such user (but not other Users) in its possession.
- In case the User does not provide his/ her information or consent for usage of Personal
Information or subsequently
withdraws his/ her consent for usage of the Personal Information so collected, MSB
reserves the right to discontinue the
services for which the said information was sought.
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Additional notes to the User:
- MSB does not exercise control over the sites displayed as search results or links from
within its Services. These other
sites may place their own cookies or other files on the Users' computer, collect data or
solicit Personal Information
from the Users, for which MSB is not responsible or liable. Accordingly, MSB does not
make any representations
concerning the privacy practices or policies of such third parties or terms of use of
such websites, nor does MSB
guarantee the accuracy, integrity, or quality of the information, data, text, software,
sound, photographs, graphics,
videos, messages or other materials available on such websites. MSB encourages the User
to read the privacy policies of
that website.
- MSB shall not be responsible in any manner for the authenticity of the Personal
Information or Sensitive Personal Data
or Information supplied by the User to MSB or any Seller. If a User provides any
information that is untrue, inaccurate,
not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or
MSB has reasonable grounds to
suspect that such information is untrue, inaccurate, not current or incomplete, MSB has
the right to suspend or
terminate such account at its sole discretion.
- MSB shall not be responsible for any breach of security or for any actions of any third
parties that receive Users'
Personal Information or events that are beyond the reasonable control of MSB including,
acts of government, computer
hacking, unauthorized access to computer data and storage device, computer crashes,
breach of security and encryption,
etc.
- The User is responsible for maintaining the confidentiality of the User's account access
information and password. The
User shall be responsible for all uses of the User's account and password, whether or
not authorized by the User. The
User shall immediately notify MSB of any actual or suspected unauthorized use of the
User's account or password.
- MSB will communicate with the Users through email and notices posted on the Website or
through other means available
through the Service, including text and other forms of messaging. The Users can ask MSB,
by sending an email to
care@mecuresmartbuy.com containing the
rectification required.
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Changes in the Privacy Policy:
- MSB may update this Privacy Policy at any time, with or without advance notice. In the
event there are significant
changes in the way MSB treats User's Personal Information, MSB will display a notice on
the Website or send Users an
email. If a User uses the Service after notice of changes have been sent to such User or
published on the Website, such
User hereby provides his/ her/ its consent to the changed practices.
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Complaints and Grievance Redressal:
- MSB addresses discrepancies and grievances of all Users with respect to processing
of information in a time bound
manner. For this purpose, MSB has designated Mr. Arjun Udani, Executive Director who
will redress the grievances of the
Users expeditiously but within one month from the date of receipt of grievance, and
who can be reached by:
-
Sending a letter marked to the attention of “Executive Director, Me Cure
Smartbuy Nigeria Limited to 23, Coker Road,
Ilupeju, Lagos. Nigeria, or
- Sending an email to care@mecuresmartbuy.com