Welcome to the privacy policy of Ithaka, a platform owned and developed by Aviro Health Ltd and being used by our distribution/implementation partners (“we” or “us”) for supporting and guiding you through the process of HIV testing and taking the next steps.   

Personal Data We Collect

When you register to use Ithaka, and at times throughout your journey, you may provide us with the following Personal Data:

  • Identifying and contact information: You provide us with your name, mobile telephone number, gender, language preference, and date of birth.  
  • Information about your health condition: You provide (or via your healthcare provider) us with information relating to your health, your medical condition and diagnosis, in particular your HIV status.This includes information you provide on your  medical records prepared by your healthcare provider (for example blood tests, diagnostic reports, treatment history, examination results, assessments by treating physicians, treatment and/ or interventions, prescription information).

How We Use Your Personal Data
We use your Personal Data in order to:

  • Support your health journey via Ithaka: We use your Personal Data in order to customize and adapt Ithaka to your specific condition and diagnosis in order to provide you with initial and ongoing support and communicate with you and your healthcare provider in connection with your health journey.
  • Detect and prevent fraud: We use your Personal Data to verify your identity in order to detect and prevent fraud, identity theft, or abuse of our services.
  • To optimize and improve our services: We use your Personal Data, together with that of other patients, to gain insights into how Ithaka is used and how to improve our services and support.

If you do not provide this Personal Data, we would not be able to provide this support to you.  We process your Personal Data comprising of health information as described above for reasons of public interest in the area of public health.

Your Rights and Your Personal Data
You are entitled to:

  • receive copies of your Personal Data under certain circumstances;
  • have the processing of your Personal Data restricted where you dispute its accuracy, if you think its processing is unlawful, or if you otherwise object to its processing, or when we no longer need your Personal Data and you need it in relation to a legal claim; and
  • request the correction or deletion of erroneous or incomplete Personal Data to the fullest legally permissible extent.

To exercise these rights, please contact us using the contact information below.

How We Share Your Personal Data
We may share your Personal Data with other entities, with third party service providers that help us in providing and supporting Ithaka, with your healthcare providers, and as may be required by law and for protecting our rights.

  • With other entities: We share your data with your health provider and its affiliates and subsidiaries for the management of the patient relationship and in the ordinary operation of our business. In addition, we would share your Personal Data if we are involved in a merger, acquisition, consolidation, change of control, or sale of all or a portion of our assets, or if we undergo bankruptcy or liquidation.
  • With your healthcare provider: We share your information with your healthcare provider as may be necessary in connection with your diagnosis.
  • With our service providers: We share your information with service providers to help us deliver Ithaka to you and to support you throughout your journey. This includes the information technology vendors who provide hosting services for our patient database and specifically with Google, who manages Firebase, the platform Ithaka is built on. Any Personal Data we provide to third party service providers will be protected by an appropriate agreement ensuring that it is only used for the purposes for which it was provided.

Additionally, we may share your Personal Data in order to prevent fraud or abuse to our services, in accordance with any applicable law, regulation, legal process, or enforceable governmental request, or when directed to by state authorities.

Retention of Your Personal Data
We will retain your Personal Data for as long as is necessary for the purpose for which you provided it and in accordance with our Records Retention Schedule developed in compliance with applicable data protection laws. We may retain your Personal Data for a longer time to the extent that we are obliged to retain your Personal Data, in accordance with applicable laws and regulations, and/or as necessary to protect our legal rights or for certain business requirements.

Safeguards Protecting Your Personal Data
The safety of your Personal Data is an important concern for us. We take appropriate steps, including technical, administrative, and physical security measures to protect the Personal Data provided to us against loss, misuse, and unauthorized access, disclosure, amendment, and deletion.

Where to Address Your Questions or Complaints
If you would like to exercise these rights, or if you have any concerns as to how your Personal Data is processed, you can contact your written concerns to the following address:

Luke Shankland, luke@avirohealth.com, 19 Kent St, Woodstock, Cape Town, 7915, South Africa

Effective as of 25 May 2018

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