PRIVACY POLICY

Privacy Policy

Date of Last Revision: June 28, 2018 
 
Higowell Limited (“Higowell”) manages www.higowell.com, a medical tourism technology platform to distribute the medical tourism services. Higowell is committed in respecting the privacy of every person and every organization that accesses this website or avails its products and services through this website (together referred to as "Services"). You may share your personal information upon accessing this website or by availing our Services. Your privacy is important to us and we strive to take reasonable care and protection of the information we receive from you.
 
This privacy policy applies to the Higowell platform users (“Users”). Users may include medical service providers (e.g. hospitals and clinics), medical tourism facilitators and ancillary service providers (e.g. spa, language translators, hotels and other travel suppliers). This privacy policy is NOT applicable to the User’s customers or medical travelers and should not be communicated to them as the user’s policy.
 
The purpose of this Privacy Policy ("Policy"), as amended from time to time, is to give you an understanding on how we collect, use and disclose the information you provide to us. Higowell takes a proactive approach to user privacy and ensures the necessary steps are taken to protect the privacy of its users throughout their visiting experience.
 
By accessing, you consent to the collection and use of your Personal Data as described herein the policy. If you do not agree with the terms set out herein, please do not visit this website. If you use the services on behalf of someone else (such as your child, relative, friend, associate) or an entity (such as your employer), you represent that you are authorized by such individual or entity to accept this privacy policy on such individual’s or entity’s behalf.
Any consent on your part is entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this service may not be permissible.
Higowell ("us", "we", or "our") operates the website and service (the "Service") and will be the “controller”, as defined in the Directive and the GDPR.
 
Information we collect
The information may be divided into the following general categories:
 
1. Information you provide to us
When you register with this website or access the website or avail the Services, we may ask you to voluntarily provide us certain information that helps facilitate your use of the platform and helps us stay compliant with our Legal obligations.
 
1.1 Personal Information
When you register with this website or access the website or avail the Services, we may ask you to voluntarily provide us certain information that personally identifies you or could be used to personally identify your entity (“Personal Information”). Personal Information includes (but is not limited to) the following categories of information: age, gender, first and last name, birth date, title, zip code/pin code, occupation, industry, personal interests, company or any other physical address, contact number, email or other contact information and other relevant data as desired by us. Questions or comments submitted by visitors may also be regarded as Personal Information
 
1.2 Communications with us and other Members
When you communicate with us or use the Platform to communicate with other Members, we collect information about your communication and any information you choose to provide. We collect this information for the purposes of maintaining safety, ensuring quality, and optimizing our services.
 
1.3 Order/Credit Information
While using our Service for making a payment, we may ask you to provide us with certain information that will help us to process the order. Information may include, but is not limited to, your name, company name, address, email address, phone number(s).
 
Health Information
This applies to you only if you are a provider of Medical Tourism facilities connecting with medical service providers and/or ancillary service providers. You may be required to provide health related information of your clients. This information is used/ stored/ processed by Higowell only for the purposes of facilitating you to find a medical service providers and/or ancillary service providers for your client and communicating the said information to the medical service providers and/or ancillary service providers. We understand that this information is sensitive and Higowell takes strict security measures to safeguard the same from any potential breach. 
 
Information which we automatically collect
When you register with this website or access the website or avail the Services, we may automatically collect certain information that helps facilitate your use of the platform and helps us stay compliant with our Legal obligations. We may also collect certain information from third-parties when you access the website of a third party or avail the services of a third party, 
 
2.1 Non-Personal Information
We may additionally collect and track Non-Personal Information about your website visit including the domain name and the name of the web page from which you use our Services, how much time you have spent on each of our web pages, the Internet Protocol (IP) address associated with your computer, operating system and platform, transaction history, pages viewed, information searched for or requested for and other relevant statistics. We will use this information for the purposes of improving the performance and operations of our website and Services. If you send us a message, this message can be stored to process it, to compile statistical information, to improve our services and support, or to get in touch with you.
 
2.2 Location Information
The Services provided by Higowell are location based services. When you use certain features on our Platform, we may collect information about your precise or approximate location through third party application(s) to offer you an improved user experience. Mobile devices allow you to control or disable the use of location services. Disabling such services may result in limited access to certain features on our platform.
 
2.3 Billing, Collection and Payment Information
When you make a payment through our site, your payment information is processed by a payment processing partner. With your payment authorization, they may collect provided payment information necessary to process your payment. The associated partner may use and store information it collects through its payment processor; which is governed by its applicable terms of service and privacy policy. We may receive certain information from the associated payment processor which will help us facilitate your order/payment and your use of the platform.
 
How we use the Information
We use the personally identifiable information you provided to us along with automatically collected information we receive to facilitate and optimize your use of the platform. This conducted by us through, but not limited to customization, website development, maintaining a safe environment and compliance to our legal obligation.
 
1. Facilitate your use of the Platform
We use the information we collect about you to establish your account and provide services; provide customized content to you; communicate with you through email and phone, send you Emails to inform you about our new products, services and offers; promotional messages and web analytics data, provide feedback to third party businesses; and take action regarding unlawful or harmful activities. You may opt out of the promotional emails anytime by intimating us of your preferences. 
 
2. Promote and Customize the Platform
We may use your email address or phone number (if provided) to contact you regarding any changes to the platform; system maintenance and outage issues; account issues; or otherwise to troubleshoot problems. We may also send you information about related services and selected third party information.
 
3. Creating a Safer Platform
We may limit or restrict your use of our website and its associated features in response to possible signs of abuse. We may remove content, under our own discretion, that may be illegal or we may deem as inappropriate. As a result of these actions, we may further suspend or disable your account due to violations against our preset Terms and Conditions and/or Privacy Policy.
 
4. Disclaimer
We do not sell, rent or trade your personal information to third parties for marketing purposes. This does not include passing on your personal information to trusted third parties who aim to assist us in operating our website/application, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. Non-personal identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
 
Disclosure of your Information
We may disclose your information to third parties; as stated below, which helps us facilitate your use of the platform and helps us comply with our legal obligations. By using this website, you hereby give us the permission to disclose your information as per the terms of this policy. We will never sell your personal information, or pass it to third parties for marketing purposes without your permission.
 
1. Business Transactions
We may disclose your personal information if we are approached by a potential buyer of our business, if we required to do so by law or in good-faith believing such action is necessary to comply with the law. In case of a sale of assets, a bankruptcy, or an insolvency event, then we may sell, transfer or share some or all of our assets, including your information to another party. In this event, we will notify you before your personal information is transferred and/or becomes subject to a different privacy policy.
 
2. Legal Obligations
We will disclose your personal Information where required to do so by law, under a subpoena, or if we believe that such action is necessary to comply with the law. We may also disclose personal information to protect the security or integrity of our service on reasonable requests from law enforcement agency.
 
3. Data Processor
We may disclose your personal information with associated third parties such as our subcontractors or our service providers who act on our behalf. We may also use a third-party data processor to process your information on our behalf. They may be identified as follows:
 
3.1 Service Providers
We may employ third party companies and/or individuals to facilitate our services, to provide the service on our behalf, to perform service-related services, or to assist us in analyzing how our service is used. These third parties will have access to your personal information for the sole purpose of performing these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
 
3.2 Communications
We may use your personal information to contact or inform you with newsletters, promotional materials and/or other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any of the emails we have sent.
 
3.3 Payment Provider
To facilitate the payment process, we may provide a third party payment provider with relevant personal information to processes all payments you may make on our website.
 
3.4 Analytics Information
In addition, we may use third party services such as Google Analytics that collect, monitor and analyze information in order to increase our Service's functionality. These third party service providers have their own privacy policies addressing how they use such information.
 
Other Important Information
 
1. Retention Period
The information collected namely personal information, log data, analytical information, location information and other information as stated in this policy will be retained by Company for the period wherein the data is essential for achieving the purpose of data processing.
 
2. Links to other website/applications
This privacy policy applies to our website and services. The website may contain links to other website or applications over which we have no control over and thus not responsible for. These website or applications may have their own policies regarding privacy which may be different than ours. We are not responsible for the privacy policies or practices of other website or applications which you access from this website or application. If you choose to visit an individual, a business, or advertiser’s website/application by “clicking on,” or subsequently redirected to a third party link located on our website/application, you will be directed to that third party’s website/application and subject to their terms & agreement and privacy policy. When we link a website/application or present an advertisement, it is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of any such third party’s privacy security policies or practices.
 
If you access the stated linked websites/applications, you are at your own risk. It is best practice to check the privacy policies, if available, of those individual website/applications to see how the operators of those third-party website/applications will disclose or use your personal information. The information you choose to provide to or that is collected by these third parties is not covered by our privacy policy.
 
3.  Access/Accuracy
To the extent that you provide us with your Personal Information, we wish to maintain your Personal Information accurate at all times. If you need to update or correct your Personal Information for any reason, you may update this directly yourself or send updates and corrections to us at dataprotection@higowell.com and we may take all reasonable efforts to incorporate the changes in your Personal Information within a reasonable period of time.
 
4. Children's Privacy
Protecting the privacy of every minor is equally important to us. The website and Services are not structured to attract minor children less than thirteen (13) years and you hereby acknowledge that you are above the age of thirteen (13) years while availing the Services.
 
5. Governing Law
This privacy policy has been construed in accordance with and shall be governed by the laws prevalent in province of Leinster, Ireland and the provisions of GDPR.
 
Cookie Policy
 
1. Cookie Policy
This website uses cookies to enhance the user’s experience while visiting the website. Where applicable, this website uses a cookie control system allowing the user to choose whether to allow the use of cookies on their computer / device on their first visit. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.
The cookies in use can be categorized as follows:
 
1.1. Analytical cookies 
Analytical cookies anonymously remember your computer or mobile device when you visit our website.  They keep track of browsing patterns and build up a profile of how our readers use the website.  We might use the given information to display relevant advertisements to you on our websites.
 
1.2. Product cookies
Product cookies help us to make our website work as efficiently as possible such as remembering your registration and login details, remembering your settings preferences, and metering the number of pages you are viewing for the purpose of administering subscriptions.
 
1.3. Third party cookies
Third party cookies such as advertising and analytics cookies are placed by or on behalf of independent advertisers who are advertising on our site. These cookies may be placed within the advertisement and elsewhere on our site. They are anonymous and cannot identify individuals. They are used for statistical analysis by allowing the advertiser to count how many people have seen their advertisement or have seen it more than once. They might also allow the advertiser to tailor advertising to you when you visit other websites. We have no access to third party cookies and third party organizations have no access to ours.  The third party organizations that place cookies have their own strict privacy policies.
 
2. Disabling Cookies
If you would like to restrict the use of cookies, you can control this function in your internet browser. Links to steps on how to do this for the most popular Internet browsers are provided below for your convenience. We are not liable for any information provided on these third party websites.
 
2.1 Internet Explorer
Link: http://windows.microsoft.com/en-GB/windows7/Block-enable-or-allow-cookies
 
2.2 Google Chrome
Link: https://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647&p=cpn_cookies
 
2.3 Mozilla Firefox
Link: http://support.mozilla.org/en-US/kb/Blocking%20cookies
 
2.4 Apple Safari
Link: http://docs.info.apple.com/article.html?artnum=32467
 
Data Subject’s Rights
GDPR, to which we adhere to in its entirety, provides for rights of the Data Subject. You, as the Data Subject, have a right to require information about your data being processed and correction of any incorrect data. You also have the right to lodge a complaint with a supervisory authority, right of Data Erasure, Data Portability and Right to Access subject to the provisions of GDPR. The information, within the meaning of this clause, shall be provided free of charge unless the request is “manifestly unfounded or excessive”.
 
Updates to Privacy Policy
We reserve the right to modify this privacy policy at any time. All changes made to this privacy policy will be posted on our website, as a blog post, by email, or through any method we determine. The most recent privacy policy will be posted first and will be identified at the top of this privacy policy page by its effective date.
Please review the changes carefully. If you disagree with the privacy policy, you must stop using the services provided by this website and the website/application all together.
 
Contact Us
If you have any questions about this Privacy Policy or for exercising the right of Data Erasure, Data Portability and Right to Access subject to the provisions of GDPR, please contact us at dataprotection@higowell.com.