Updated: March 25, 2022
This Policy outlines the policy of E.V. Assistant Software Services, Inc. (“EVA” or “We”)1 in relation to the collection, use, processing, sharing, storing, and protection of your Personal Data. From time to time, we may update our Policy to reflect required changes or updates. When we do so, we will post the changes or updates in our website www.evadigitalclinic.com.ph (“Website”) for your information and reference. If the changes or updates involve your Personal Data requiring your consent, we will obtain your consent prior to posting these changes or updates.
2. Rights as Our Customer.
We are mindful of your rights under the Data Privacy Act of 2012, and that you should be the ultimate decision-maker on matters involving your Personal Information. When you signed up to be a customer of E.V. Assistant Software Services, Inc. (“EVA”), and for as long as you are a customer, you consented to, and until your subscription expires or is terminated, you continue to consent to, our collecting, processing, using, sharing, storing, and eventually destroying of your Personal Data for the purpose of providing you with the products and services you have subscribed to or may want to subscribe to as well as for other uses identified in Section 5 of this Policy.
All throughout the term of your subscription to EVA you may at any time exercise your right to revise the Personal Data you have given, refuse access, processing, or use of your Personal Data, withdraw consent previously given to the access, processing or use of your Personal Data, or object to the same. You are aware that by withdrawing your consent, or objecting to the processing of your Customer Data, EVA will not be able to provide you with the products and services you have subscribed to or may want to subscribe to.
Information provided to you via EVA will be in clear and plain language to ensure that this information is easy to understand and access. You have the right to seek indemnity for damages sustained, if any, due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your Personal Information. Should you feel that there has been mishandling or misuse of your Personal Information, or that any of your data privacy rights have been violated, you may email us at firstname.lastname@example.org.
3. Third Party.
In order to fully comply with our obligations to our customers, we may outsource or contract the access to, processing, and use of Personal Data to third parties, such as but not limited to, our subsidiaries, affiliates, partners, third party service providers or other telecommunications operators. They may have access to Personal Data for a limited time under reasonable contractual and technical safeguards to limit their use of such information. We require them to protect Personal Data consistent with our Policy. As far as our customers are concerned, EVA will be responsible for any breach, committed by these contracted third parties, of the Policy, of Republic Act No. 10173 or the Data Privacy Act of 2012 (the “Act”) and its Implementing Rules and Regulations (the “IRRs”) or of other relevant laws.
4. Collection of Personal Data.
As a customer of EVA, you give your express consent to our collecting and processing of your Personal Data. This consent shall remain in effect until you withdraw consent to specific activities done on your behalf, or your subscription expires, or your subscription is terminated.
Your data that we collect, process, use, and share are either “Personal Information” as defined under the Act or non-Personal Information:
(i) ”Personal Information” is any information from which the identity of an individual may be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual, such as name, gender, date of birth, address, telephone/mobile number, email address and proof of identification. It also includes information about:
(a) medical and health information;
(b) the services provided to you, such as, call/SMS details, location information, and certain information about your rate plans and features, as required by law;
(c) the location of your device whenever it is switched on, if you subscribe to location-based services, subject to coverage limitations; and
(d) your use of our service, service experience, and other service issues to help us improve the quality of our services, determine tailored content, and for other legitimate business purposes.
(ii) “Non-Personal Information” is any information that does not identify you on an individual basis, and includes statistical and analytical data, and anonymous and aggregated reports.
We may also request you to update your Personal Data at the Website www.evadigitalclinic.com.ph from time to time. Should you be unable to supply us with the Personal Data requested for, we may be unable to provide you with products and services you wish to subscribe to, and updates on EVA’s latest offerings. You may also be unable to participate in our events, promotions or other activities.
5. Use of Customer Data.
As a customer of and until you terminate your subscription with EVA, you continue to consent to our using your Personal Data as follows:
We use Personal Data to: (i) Enable you to register with and subscribe to EVA; (ii) Avail of the services of EVA and the licensed physicians; (iii) Provide you with your other subscribed products and services, including customer support; (iv) Enhance your customer experience and identify tailored content to meet your preferences and needs; (v) Communicate relevant services and/or advisories to you; (vi) Abide by any safety, security, public service or legal requirements and processes; (vii) Send offers and other promotional communications (viii) Notify you when Website updates are available; (ix) Send you information about additional healthcare services or general wellness from us or on behalf of our affiliates and Partners; (x) Improve the quality of healthcare through the performance of quality reviews and similar activities; (xi) Fulfill any other purpose for which you provide us Personal Information; and (xii) For any other purpose for which you give us authorization;
Only Personal Data necessary for the services which EVA offers and which you have subscribed to will be obtained from you and processed to enable you to avail of the services of the licensed physicians. Additional Personal Data may be required from you should you desire to avail of the other products and services offered. We may use your Personal Data to the extent necessary to comply with the requirements of the law and legal process, such as a court order; to comply with a legal obligation; or to prevent imminent harm to public security, safety, or order. We use your Non-Personal Information for statistical, analytical, and research purposes to create anonymous and aggregated reports. We commit to process your Personal Data fairly and lawfully, in a manner that will be transparent to you, to allow you the option to know the nature and extent of processing. We will seek your consent in case we will use or process your Personal Data for any purpose other than those listed under this Section 5, or if required by Law or our Policy. You may avail of our broadcast messages relevant to you through written correspondence, text messaging, internet, or other similar means of communication. You may also change your mind at any time and opt out of receiving them by contacting the EVA Chat Support on EVA’s website and Facebook Account.
6. Protection of Customer Data.
We respect your privacy. We take paramount care in protecting your Personal Data. As such, we secure and protect your Personal Data with proper safeguards to ensure confidentiality and privacy; prevent loss, theft, or use for unauthorized purposes; and comply with the requirements of the Law, specifically the Data Privacy Act of 2012 and its implementing rules and related laws, circulars, and issuances.
As communications over the internet may not be secure, we take reasonable and appropriate security measures that use a variety of physical, electronic, and procedural safeguards to protect Personal Data. For example, we protect and keep your information submitted through our Website safe using a secured server behind a firewall, encryption, and other appropriate security controls. When you enter your information through our Website, we encrypt that information using Secure Sockets Layer (SSL) technology so that it cannot be read as the information travels over the internet. We regularly review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to our system and unauthorized alteration, disclosure, or destruction of information we are in possession of.
We only permit your Personal Data to be accessed or processed by our authorized personnel who will have access to and hold such information under strict confidentiality. We restrict access to information to selected and qualified EVA employees, contractors, agents, representatives, Partners, affiliates, and other third-party service providers including the licensed physicians, who have a “need-to-know” in order to process this information, who are subject to strict contractual and technical safeguards and are accountable to the law, the customers, and to EVA, if they fail to meet these obligations.
We keep your Personal Data in our records, as may be applicable, while you are our customer, or as long as it is necessary to fulfill the purpose for which it was collected, or while it is needed by us for business, tax, or legal purposes. Disposition of Personal Data shall be done in accordance with the law, in a secure manner that would prevent further processing, unauthorized access, or to ensure that disposed information is not accessible to the public.
Your Personal Data remains your property. We are not responsible for information, content, application, product, or service that we do not own or provide. We will take all measures to fight spam, fraud or any unauthorized messages that may attempt to or do traverse our network.
7. High-Level Privacy Principles.
a. Purpose and Use. We will limit the access, collection, sharing, disclosure, and further use of your Personal Data to legitimate business purposes as outlined in this Policy or to otherwise meet legal obligations.
b. Data Minimization. We will collect, access, and use only the Personal Data necessary to meet legitimate business purposes as outlined in this Policy.
c. Respect User Rights. You will be provided with information about, and an easy means to exercise, your rights over the use of your Personal Data on our Website at EVA Chat Support on EVA’s Website and Facebook Account.
d. Security. Personal Data will be protected, using reasonable safeguards appropriate to the sensitivity of the information; and
e. Enforcement. All responsible persons will be accountable for ensuring that these principles are met. You have the right to lodge a complaint before the relevant government agencies, including the National Privacy Commission of the Philippines.