HSP Group recognises and respects the right to privacy and dignity of all persons including its clients, patients, 3rd parties, investors, website visitors and users (“you”).

When you interact through our HSP Group website or make use of any products and services, all personal information will be treated as confidential and protected from unauthorised use, access, loss, or damage.

This Privacy Policy manages the way that we treat your personal information and is designed to help you understand how personal information is collected, used, stored and shared when you visit our website and/or use any products and services. If you do not agree to the terms of this Privacy Policy, you may choose not to use our website, and/or products and services and not submit any personal information.

1. What is Personal Information?

Personal information means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:

• information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
• information relating to the education or the medical, financial, criminal or employment history of the person;
• any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
• the biometric information of the person;
• the personal opinions, views or preferences of the person;
• correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
• the views or opinions of another individual about the person; and
• the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.

2. What Personal Information is collected?

When you visit, browse, or interact on the HSP Group website, the following personal information about you may be collected:

• Name and Surname
• Identity/Passport Number
• Contact details
• Email address
• Location
• Health information
• Information relating to your computer’s Internet Protocol (IP) address, browser type, browser version, the pages of our website that you visit, the date and time of your visit, the duration of time spent on the website pages, and other applicable statistics.
• Financial information regarding a franchise opportunity

Personal information may also be collected from you directly when you visit our clinics or make use of our on-site services.

Where the law requires that information regarding certain diseases be notified to the authorities, HSP Group will do so without delay.

HSP Group may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information, but is not considered personal information in law as this information does not, directly or indirectly, reveal your identity.

3. Purposes for which HSP Group uses your Personal Information:

Any information collected from you may be processed for, amongst others, the following purposes:

• To provide you with products and services;
• To make an appointment;
• To assess your psychiatric, psychological or addictive condition;
• To assess any medical treatment you may require;
• For statistical and research purposes;
• To comply with legislative requirements;
• To process your application for a vacancy; or
• To detect, prevent or deal with actual or alleged fraud, security breach, or the abuse, misuse or unauthorised use of the website and/or contravention of this Privacy Policy.

4. Categories of Personal Information

HSP Group processes many different categories of personal information including, but not limited to:

• Contact details, such as phone numbers, physical and postal addresses, and email addresses;
• Personal details, such as names, family information, and ages;
• Demographical details, such as race and age groups;
• Health information;
• Biometric information;
• Financial information, such as account numbers;
• Credit information;
• Special personal information as it may relate to your medical treatment;
• Market intelligence information that may relate to your well-being; and
• Background information.

5. Protection of your Personal Information

HSP Group takes the security of your personal information very seriously.

HSP Group recognise the vital role that information technology plays in its daily operations, and the reliance placed on IT systems in processing personal information. Although absolute security cannot be guaranteed, HSP Group will take reasonable technical and organisational measures to protect your personal information against accidental, unauthorised or intentional manipulation, loss, misuse, destruction, disclosure or access.

HSP Group’s security measures are regularly verified for its operating effectiveness. Reasonable mechanisms, tools and technologies have been implemented to detect, prevent and respond to security violations. Information security policies and procedures that govern security safeguards are in place, including dedicated teams and business processes to govern instances of non-compliance with privacy policies, procedures or applicable law.

6. Disclosure of your Personal Information

HSP Group may disclose your personal information if authorised to do so by law.

HSP Group also engages with various third parties, to improve its service, create efficiency in its operations, and contribute towards the overall wellbeing of users and patients.

HSP Group will share your personal information if:

1. you have provided consent;
2. it is for the proper treatment and care of yourself; and/or
3. it is in accordance with applicable law.

When HSP Group shares your information with any third party, they will be required to respect your right to privacy and HSP Group will ensure that they have the necessary safeguards in place to secure your personal information. HSP Group will only allow third parties to process your personal information for a specific purpose, in accordance HSP Group’s instructions and applicable law.

7. Retention of your Personal Information

HSP Group may retain all personal information that is collected from you, as long as it remains necessary for the purposes for which it was collected unless there is a valid technical, legal or business reason for it to be deleted, destroyed or to de-identify it.

Patient records will be kept in our patient management system as long as they are required for the purpose for which they were collected.

HSP Group may keep some of your personal information:

• for as long as it is required by law;
• if it is required by a code of conduct;
• if it is reasonably needed for lawful purposes related to HSP Group’s functions and activities; or
• it is reasonably needed for evidentiary purposes.

8. Direct Marketing

HSP Group may use your data for marketing purposes, however HSP Group will in all circumstances enable an unsubscribe or opt out function is contained in our marketing materials, should you not wish to receive marketing material.

To ensure continuous improving of the care and service offering, patients may be asked to complete service experience questionnaires.

9. Storage and transfer of your Personal Information

HSP Group stores your personal information on its servers and/or on third party servers. HSP Group reserves the right to transfer to and/or store your personal information on servers in a jurisdiction other than where it was collected. If the location where personal information is transferred to does not have substantially similar laws which provide for the protection of personal information, HSP Group will take reasonably practicable steps to ensure that your personal information is adequately protected in that jurisdiction.

10. Cookies

HSP Group uses Cookies to understand your online activity, and save your preference for future visits. A cookie is a small piece of data sent from our website to your computer or device or internet browser where it is saved. The cookie contains information to personalize your experience on the HSP Group website and applications. The cookie has the ability to identify your device, computer or smart phone. By using the HSP Group website and applications you agree that cookies may be forwarded from the relevant website or application to your computer or device. HSP Group may use the cookie to confirm that you visited the website. You have the right to choose whether or not to accept cookies. However, please note that if you do not accept the cookies, you may not be able to use the full functionality of the website or mobile applications.

11. Other websites linked to this site

When you interact with any HSP Group website, you may come across links to other websites and applications. HSP Group is not responsible for the security of those websites, or the information that it contains. In some cases, links are provided as a value added service for information purposes only. Please remember that when you click on a link on the HSP Group website and you are taken to another web page or website or application that this Privacy Policy will no longer apply. You also acknowledge that by clicking on a link, that you do so at your own risk and hold HSP Group harmless against any loss or damage that may occur

12. Changes to this Privacy Policy

From time to time, changes will be required to this Privacy Policy. Please check this website to inform yourself of any changes made to this Privacy Policy.

13. Your Rights

HSP Group will, at all times, process your personal information in accordance with applicable laws and your rights are set out below:

• You have the right to correct your personal information if it is incorrect;
• You have the right to update your personal information if your details have changed;
• You have the right to object to the processing of your personal information;
• You have the right to your personal information being deleted; and
• You have the right to be informed if your information has been deleted.

If you would like to exercise any of your rights:  please email your request to info@hspgroup.co.za

You acknowledge that, in some cases, HSP Group may not be able to comply with your request to delete or destroy your personal information if this request conflicts with applicable law.

14. Information Regulator

You have the right to complain to the Information Regulator, whose contact details are: Information Regulator Tel: (012) 406 4848 Fax: 086 500 3351 Email: Inforeg@justice.gov.za

15. Important Information

If you have any questions regarding the contents of this policy you may address those concerns in writing to info@hspgrpup.co.za

Upon clicking the link to this policy, we accept that:

1. You have read the contents of this policy;
2. You understood the contents of this policy;
3. You are in agreement with the contents of this policy;
4. You have no objections to your personal information being managed in this way by HSP Group; and
5. That you have no questions regarding the contents of this policy.