• This Privacy Policy (“Policy”) outlines TotalHealth.lk (Private) Limited’s (“Company”, “TotalHealth.lk”, “we”, or “us”) practice in relation to the storage, use, processing, and disclosure of personal data that you have chosen to share with us when you access our website http://TotalHealth.lk “TotalHealth.lk” (collectively, the “Platform”) and when you interact with customer service and promotional activities conducted by us.


• At TotalHealth.lk, we are committed to protecting your personal data and respecting your privacy. Please read this Policy carefully to understand our practices regarding your personal data and how we will treat it. The Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.


• This Policy together with our Terms applies to your use of the Platform through your phone, computer, or other device (“Device”) and of the services accessible through the Platform (“Services”).


• Unless defined in this Policy, capitalized words shall have the same meaning ascribed to them in our Terms and Conditions (“Terms”), available at http://TotalHealth.lk. Please read this Policy in consonance with our Terms.


• By using the Platform, you consent to the collection, storage, use, and disclosure of your personal data, in accordance with, and are agreeing to be bound by this Policy. We will not collect any information from you, except where it is knowingly and explicitly provided by you.

1. THE DATA WE COLLECT ABOUT YOU

• We may collect, use, store, and transfer different kinds of personal data about you in connection with your use of the Services, including but not limited to:
  • identity data, including your name, username, date of birth;
  • We might require you to share information, including information pertaining to your identification in the process of creation of the User Account. You agree that all information provided in this regard is complete, true, and accurate. Separately, you should ensure the confidentiality of details of the User Account, including usernames and passwords. Please note that all personal information shared with us shall be treated and processed in accordance with our Privacy Policy.
  • contact data including your email address and phone number, billing address, delivery address;
  • financial data including payment card details;
  • transaction data including details of Services you have availed and details of payments you have made on the Platform;
  • technical data including IP address, login data, time zone setting and locations, operating system and platform, and other technologies on your Device used to access the Platform;
  • profile data including your username and password, preferences, feedback, and survey responses;
  • usage data including how you use the Platform and Services;
  • data that your healthcare providers may choose to upload or otherwise store on the Platform. Please note that healthcare service providers on the Platform are bound by duties, including statutory duties, of confidentiality in relation to any health or medical information, data, and history that you choose to share through the Platform;
  • Marketing and communications data including your preferences in receiving marketing from us and your communication preferences.
• We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the Platform. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
• You do not have to supply any personal data or information to us but in doing so, you may not be able to take advantage of all the Services we offer.
• If you would like a copy of the personal information you have provided to us, please reach out to us as provided in Paragraph 12.

2. HOW IS YOUR PERSONAL DATA COLLECTED?

• We will collect and process the following data about you:
• "Information you give us "- This is the information (including identity, contact, financial, health and marketing and communications data) you consent to giving us about you by filling in forms on the Platform, by using our Services or corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Platform, download or register or subscribe to any of our Services, search for a Service, make an in-Platform purchase, share data via Platform’s social media functions, enter a competition, promotion or survey, or other activities commonly carried out in connection with the Platform, and when you report a problem with the Platform and our Services. If you contact us, we may keep a record of the information shared during the correspondence.
• Information we collect about you and your device ”- Each time you visit our Platform or use one of our Services, we will automatically collect personal data including technical and usage data. We collect this data using cookies and other similar technologies.
• "Information we receive from other sources including third parties and publicly available sources - "We will receive personal data about you from various third parties and public sources including those set out below:
  • Analytics providers such as Google and Facebook;
  • Advertising networks;
  • Search information providers;
  • Contact, financial and transaction data from providers of technical, payment and delivery services;
  • Identity and contact data from data brokers or aggregators;
  • Identity and contact data from publicly available sources;
  • Data inserted by the Healthcare Provider providing your services on the Platform; and
  • Other health record systems.

3. AUTHENTICITY OF INFORMATION

• We have taken all reasonable steps to ensure that the information on the Platform is authentic.
• You agree that the information and personal data you provide us with are true, correct, and accurate. We shall not be liable for any incorrect or false information or personal data that you or your Healthcare Provider might provide.
• You may review the information and personal data that you have provided during your use of the Platform and choose to correct or modify it. You may do so by writing to us or our Grievance Officer at the address provided in Paragraph 12.

4. HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSES

• You understand that when you consent to providing us with your personal data, you also consent to us sharing the personal data with third parties.
• You are aware that by using or creating an account with the Platform, you authorise us, our associate partners and affiliates to contact you via email, phone, Address or otherwise. This is to ensure that you are aware of all the features of the Platform and other relevant services.
• You authorise us to send you electronic alerts for details pertaining to registration, other service requirements, and advertising.
• Further, you agree to receive promotional and other emails and other forms of communication from us. Through such communication you will receive information about the latest developments on the Platform and other relevant services. You may unsubscribe from our mailing list at any time through the unsubscribe option we offer.
• You are aware that any and all information pertaining to you, whether or not you directly provide it to us (via the Platform or otherwise), including but not limited to personal correspondence such as emails or letters, instructions from you, etc., may be collected, compiled, and shared by us in order to render Services to you and you expressly consent to the same.
• In general, we will not disclose personal data except in accordance with the following purpose or activity:
  • to install the Platform and register you as a user;
  • to process in-Platform purchases and deliver Services including managing payments;
  • to manage our relationship with you including notifying you of changes to the Platform or any Services;
  • to administer and protect our business and this Platform including troubleshooting, data analysis, and system testing;
  • to deliver content and advertisements to you;
  • to make recommendations to you about goods or services which may interest you;
  • to measure and analyse the effectiveness of the advertising we serve you;
  • to monitor trends so we can improve the Platform;
  • to perform a contract, we are about to enter or have entered with you;
  • to enforce our Terms;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • to comply with a legal or regulatory obligation.

5. TRANSFER OF PERSONAL DATA

• As a part of your use of the Platform, the information and personal data you provide to us may be transferred to and stored at countries other than Sri Lanka. This may happen if any of our servers are from time to time located in a country other than Sri Lanka , or one of our service providers is located in a country other than Sri Lanka. We may also share information with entities of countries other than Sri lanka . These countries shall be subject to data laws of their respective countries.
• If you use the Platform while you are outside Sri Lanka (subject to the Terms), your information may be transferred to a country other than Sri Lanka in order to provide you with the Platform.
• By submitting your information and personal data to us, you agree to the transfer, storage, and processing of such information and personal data outside India in the manner described above.

6. THIRD PARTY LINKS AND USER EXPERIENCE

IMPROVEMENT SERVICES

• Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (“Third Party Websites”). Please note that the Third Party Websites and any services from them that may be accessible through our Platform have their own privacy policies. We do not accept any responsibility or liability for the policies or for any personal data that may be collected through the Third Party Websites or their services. Please check their policies before you submit any personal data to such websites or use their services.
• We use third-party user experience improvement services (including but not limited to those provided by both, Google Inc and its affiliates) and applications to better understand your behavior on the Platform. The information collected includes (but is not limited to):
  • age;
  • gender;
  • preferences; and
  • interests.
• Your relationship with these third parties and their services and tools is independent of your relationship with us. These third parties may allow you to permit or restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.
• The place of processing information depends on each third-party service provider and you may wish to check the privacy policy of each of the service providers to identify the data shared and its purpose. You will be subject to a third party’s privacy policy if you opt in to receive communications from third parties. We will not be responsible for the privacy standards and practices of third parties.

7. COOKIES

• We use cookies to distinguish you from other users of the Platform and remember your preferences. This helps us to provide you with a good experience when you use or browse our Platform and also allows us to improve the Platform.
• We collect data by way of ‘cookies’. Cookies are small data files which are sent to your browser from the Platform and are stored on your computer or device (hard drive). The cookies shall not provide access to data in your computer or device such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow us to administer the Platform and provide you with a tailored and user-friendly service. The cookies shall enable you to access certain features or both, the Platform and the Services. Most web browsers and devices can be set to notify when you receive a cookie or prevent cookies from being sent. If you do prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform.
• Additionally, you may encounter cookies or other similar devices on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by third parties. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Platform, we may collect such information into a file specific to you.

8. DATA SECURITY

• We implement certain security measures including encryption and firewalls to protect your personal information from unauthorised access and such security measures are in compliance with the security practices and procedures as prescribed under the Personal Data Protection Act no 9 of 2022 (PDPA). However, you agree and acknowledge that the above-mentioned measures do not guarantee absolute protection to the personal information and by accessing the Platform, you agree to assume all risks associated with disclosure of personal information arising due to breach of firewalls and secure server software.
• Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
• We will comply with the requirements under the Information Technology Act, 2000 and the rules made thereunder in the event of a data or security risk.

9. DATA RETENTION

• You are aware that your personal data will continue to be stored and retained by us for a reasonable period after termination of your account on the Platform.

10. BUSINESS TRANSITIONS

• You are aware that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

11. CHANGE IN PRIVACY POLICY

• We keep our Policy under regular review and may amend this Policy from time to time, at our sole discretion.
• The terms of this Policy may change and if they do, the changes will be posted on this page and, where appropriate, notified to you by email. The new Policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Platform and the Services.

12. BUSINESS TRANSITIONS

• You may contact us at info@totalhealth.lk any enquiry relating to this Policy or an enquiry relating to your personal information (for example: reviewing, updating, or seeking deletion of your information). You can also do so by writing to our Grievance Officer, established in accordance with the Personal Data Protection Act no 9 of 2022 (PDPA) and rules made thereunder, at the address provided below:

Email: info@totalhealth.lk.