Privacy

Privacy Policy

Thank you for choosing to be part of our community at GLOCASSA ("Company"). All references to the “Company,” “we,” “us”, and “our” refer to GLOCASSA and affiliated companies. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice (Privacy Notice), or our practices with regards to your personal information, please contact us at glocassa@baobabcompanygroup.com.

When you visit our websites (i.e. https://www.GLOCASSA.com/, https://myaccount.GLOCASSA.com/, https://patient.GLOCASSA.com)/, https://records.GLOCASSA.com)/ and more generally when you use any of our services (including our GLOCASSA Mobile App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously.

In this Privacy Notice, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Notice that you do not agree with, please discontinue the use of our services immediately.

This Privacy Notice applies to all information collected through our services (which, as described above, includes our websites, and our GLOCASSA Mobile App), as well as, any related services, sales, marketing or events. It does not apply to business contact information.

Information provided by organisations or individuals to us for business purposes is not considered personal data. Please read this Privacy Notice carefully as it will help you understand what we do with the information that we collect.

What information do we collect?

Summary: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you:

1. register to use our services
2. express an interest in obtaining information about us or our products and services
3. participate in activities on our websites or otherwise when you contact us

The personal information that we collect depends on the context of your interactions with us, the choices you make, and the products and features you use. The personal information we collect may include the following:

1. personal data
2. time of query
3. time of reply
4. name of client’s station - identification made through HTTP protocol
5. information about errors that occurred during the HTTP transaction
6. URL address of the website previously visited by the user (referrer link)
7. information about your browser
8. information about your Internet Protocol (IP) address

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Do you automatically collect Information?

Summary: Some information - such as your IP address and/or browser and device characteristics, is collected automatically when you visit our website or when you use our GLOCASSA Mobile App.

We automatically collect certain information when you visit, use, or navigate our websites and GLOCASSA Mobile App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services and other technical information. This information is primarily needed to maintain the security and operation of our websites, our GLOCASSA Mobile App, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

Will your information be shared with anyone?

Summary: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations.

We may process or share your data that we hold based on the following legal basis:

1. consent: we may process your data if you have given us specific consent to use your personal information for a specific purpose
2. legitimate interests: we may process your data when it is reasonably necessary to achieve our legitimate business interests.
3. performance of a contract: where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
4. legal obligations: we may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
5. vital interests: we may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

1. business transfers: we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Do we use cookies and other tracking technologies?

Summary: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. We may make use of “cookies” on our websites to store and track information such as the number of users and their frequency of use, profiles of users and their online preferences. Cookies do not capture information which would personally identify you. But the information collected may be used to assist us in analyzing the usage of our websites and to improve your online experience with us. You can disable the cookies by changing the setting on your browser. However, if you choose to remove or reject cookies, this could affect certain features or services of our websites or our GLOCASSA Mobile App.

Is your information transferred internationally?

Summary: We may transfer, store, and process your information in countries other than your own.

Our servers are in the USA. However, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE? " above), in other countries.

If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

What is our position on third-party websites?

Summary: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our services or our company.

Our websites and our GLOCASSA Mobile App may contain advertisements from third parties that are not affiliated with us, and which may link to other websites, online services, or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Privacy Notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications. You should review the policies of such third parties and contact them directly to respond to your questions.

How long do we keep your information?

Summary: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than necessary for the purposes outlined herein.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Do we collect information from minors?

Summary: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using our websites or our E-Clinic Mobile App, you represent that you are at least 18 years old or that you are the parent or guardian of such a minor and consent to such minor dependent's use of any of our services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at glocassa@baobabcompanygroup.com.

What are your privacy rights?

Summary: You may review, change, or terminate your account at any time.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/inea/en/mission-objectives/data-protection.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

1. log into your account settings and update your user account
2. contact us using the contact information provided

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our terms of service and/or comply with applicable legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our websites or our GLOCASSA mobile app.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list. However, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

1. note your preferences when you register an account with the site
2. access your account settings and update preferences
3. contact us using the contact information provided

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

Do we make updates to this notice?

Summary: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated policy shall supersede earlier versions and shall apply to personal data provided to us previously. The updated version will be indicated by an updated "Revised" date and the updated version shall be effective as soon as it is accessible. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at glocassa@baobabcompanygroup.com.

How Can You Review, Update Or Delete The Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by emailing us at glocassa@baobabcompanygroup.com. We will respond to your request within 30 days.

Data Privacy

Introduction

This Data Protection Policy (Policy) outlines our commitment to treat information of our users, employees, stakeholders, and other interested parties with the utmost care and confidentiality. With this Policy, we ensure that we gather, store, and handle data fairly, transparently, and with respect towards individual rights. We hope that this document can provide the reader with the information required to make informed and ethical decisions about how we use, access, and disclose personal data. This Policy is the cornerstone of our data protection efforts. We envision this document as an evergreen document, and we actively encourage anyone with suggestions, recommendations, or critiques to voice them. Copy of this data protection policy can be found on our website located at https://www.GLOCASSA.com/policies/privacypolicy.pdf.

Purpose

The goal of this Policy is to enhance and clarify the procedures we have implemented to safeguard sensitive data. We are committed to upholding the highest standards of data security. Our goals are to explain our core data security principles and provide information about the procedures and best practices we’ve implemented to abide by these principles.

Scope

This Policy refers to all parties (employees, users, our affiliates, etc.) who provide any amount of information to us. The provisions in this Policy also apply to all equipment owned and operated by the Company, including all network domains, websites, and mobile applications set up by the Company. The roles and responsibilities outlined in this Policy refer to any, and all employees, managers, investors, users, or contractors of the Company. Data protection is a collective effort and requires hard work, passion, and commitment from every person in this Company. Employees of our Company and its subsidiaries must follow this Policy. Contractors, consultants, partners, and any other external entity are also covered. Generally, our Policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.

Non-compliance

The Company is committed to data safety and takes a zero-tolerance approach to carelessness. Any violations of the provisions and procedures in this Policy will be disciplined as per the Company’s disciplinary action procedure, up to and including immediate termination.

Definitions

Personal data: any information relating to an identified or identifiable natural person (“data subject”).

Identifiable Natural Person (INP): INP 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.

Policy Elements

As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, IP address, and other digital footprints, photographs, social security numbers, financial data etc.

Our Company collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply.

Our data will be:

1. accurate and kept up to date
2. collected fairly and for lawful purposes only
3. processed by the company within its legal and moral boundaries
4. protected against any unauthorized or illegal access by internal or external parties

Our data will not be:

1. communicated informally
2. stored for more than a specified amount of time
3. transferred to organizations, states or countries that do not have adequate data protection policies
4. distributed to any party other than the ones agreed upon by the data's owner (exempting legitimate requests from law enforcement authorities)

In addition to ways of handling the data the Company has direct obligations towards people to whom the data belongs. Specifically, we shall:

1. let people know which of their data is collected
2. inform people about how we'll process their data
3. inform people about who has access to their information
4. have provisions in cases of lost, corrupted, or compromised data
5. allow people to request that we modify, erase, reduce or correct data contained in our databases

Actions

To exercise data protection, we're committed to:

1. restrict and monitor access to sensitive data
2. develop transparent data collection procedures
3. train employees in online privacy and security measures
4. build secure networks to protect online data from cyberattacks
5. establish clear procedures for reporting privacy breaches or data misuse
6. include contract clauses or communicate statements on how we handle data
7. establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.)

Roles & Responsibilities

It is everyone’s responsibility to read this Data Protection Policy document. It is also a collective duty to speak up about bizarre behaviors, unknown or unusual visitors, gaps in security systems, phishing attempts or lost devices and equipment.

Incident Reporting

All concerns, questions and suspected or known security incidents must be reported using one of the following methods:

1. contacting the Data Protection Officer at glocassa@baobabcompanygroup.com.

Messages sent will be directed to the Data Protection Officer (DPO) who will then identify, assess, and handle the matter in accordance with the procedures and best practices in this policy. Under no circumstances should an individual attempt to cover up or ignore a data security incident.

Incident Response Plan

Upon receiving a report of an incident, the Incident Response Team will conduct a brief preliminary investigation to confirm the incident and identify any immediate actions to remedy the issue (such as resetting passwords or erasing a piece of equipment remotely). Then, the Team will conduct a more thorough investigation of the incident to build a greater understanding of what occurred.