Privacy Policy

1. Who we are

XTEND TECH (PTY) LTD ("we", "us", "our") publishes and operates the Guud Passport mobile application. We are the responsible party for the personal information processed through the app, as that term is used in the Protection of Personal Information Act 4 of 2013 ("POPIA").

Your health assessments are carried out by Guud Global SA and the registered healthcare practitioners working at its Mobile Assessment Centres ("MACs") and through its telemedicine service. Those practitioners create and hold your clinical records in their own right and are bound by their professional and legal obligations, including the Health Professions Act and the rules of the Health Professions Council of South Africa. Guud Passport gives you access to those records; it does not replace them.

2. What this policy covers

This policy covers the Guud Passport app and the account behind it. It does not cover the clinical practice of the healthcare providers who assess and treat you, the systems your employer runs, or any third-party website we link to.

3. The information we collect

Guud Passport is an invite-only app. You get access after you have been assessed at a Guud Mobile Assessment Centre, which means most of the information in the app was created during that assessment rather than typed in by you.

Account and identity information

Health information

This is the core of what Guud Passport shows you, and it is special personal information under section 26 of POPIA:

• Primary healthcare assessment results from your MAC visit
• Eye and vision assessment results, and any spectacle prescription
• Hearing screening results
• Medical certificates and health certificates issued to you
• Medicine prescriptions issued to you
• Records and notes from telemedicine consultations you take part in

Compliance information

The licences, permits and certificates your role requires, together with their validity and expiry dates, so the app can tell you when something is about to lapse.

Technical and usage information

• A device identifier generated by our analytics tool
• Your account identifier
• Which screens and features you use inside the app, and when
• App version and platform

Crash and error information

When the app crashes or hits an error, it sends us an automatic diagnostic report so we can fix the problem. The report contains what went wrong and where in the code, the app version, your device model and operating system version, and the IP address the report was sent from.

These reports are generated by the app itself, not by anything you do. They are not linked to your name and they never contain your health information.

What we do not collect

Guud Passport does not collect your location, your contacts, your photo library, your calendar, your messages, your browsing history, or any financial or payment information. The app does not contain advertising, an advertising identifier, or any attribution or tracking software, and we do not track you across other companies' apps or websites.

Documents such as your certificates and prescriptions are downloaded to your device for you to read. Files on your device are never uploaded from it to us.

4. Where the information comes from

• From you: when you set up your account, update your details, or take part in a telemedicine consultation.
• From your assessment: the healthcare practitioners who assessed you at a Guud Mobile Assessment Centre create your clinical records, which are then made available to your account.
• From your employer or programme sponsor: where your employer has arranged the health programme, it may confirm your identity and employment so that your account can be created.
• From the app itself: usage and device information, and automatic crash reports when something goes wrong, as described above.

5. Why we process your information, and our lawful basis

Special personal information

Health information and your identity number receive additional protection under POPIA. We process your health information on the basis of your consent and section 32 of POPIA, which permits medical professionals, healthcare institutions and facilities to process health information where it is necessary for the proper treatment and care of the person concerned. We process your identity number to confirm that health information is released only to you.

You may withdraw your consent at any time by deleting your account (see section 10). Withdrawing consent does not affect processing that already took place, and it does not delete the clinical records held by your healthcare provider. See section 9.

6. Who we share your information with

We do not sell your personal information, and we never have.

Healthcare practitioners

The registered healthcare professionals who assess and treat you, including through telemedicine, have access to the clinical information necessary to care for you.

Analytics

We use Mixpanel, a product analytics service, to understand how people move through the app so that we can improve it. Mixpanel receives your account identifier, a device identifier, your name and email address, and records of the actions you take in the app. Mixpanel acts as our operator and processes this information only on our instructions.

Mixpanel does not receive your health information, your assessment results, your certificates or your prescriptions.

Crash reporting

We use Sentry to receive an automatic report whenever the app crashes or hits an error, so that we can find and fix it. Sentry receives the diagnostic information described in section 3, including the IP address the report came from. Sentry acts as our operator and processes this information only on our instructions.

Sentry does not receive your name, your email address, your account details or any of your health information.

Infrastructure and service providers

We use third parties for hosting, storage, authentication and communications. They process personal information on our instructions, under written agreements, and only to provide the service to us.

Your employer or programme sponsor

Where your employer or a programme sponsor has arranged the health programme, we report to them only in aggregate: figures such as how many of their people were assessed, or overall results across a site or workforce. Aggregated reporting does not identify anyone.

We never send your employer anything about you individually. Not your clinical results, diagnoses, prescriptions or consultation records; not the status of your licences or certificates; not even whether you personally attended.

Legal disclosures

We may disclose personal information where the law requires it, where it is needed to establish, exercise or defend a legal claim, or to protect someone's life or safety.

7. Sending information outside South Africa

Some of our service providers, including Mixpanel and Sentry, process information on servers outside South Africa, primarily in the United States. Where we transfer personal information across a border, we do so in line with section 72 of POPIA: on the basis of your consent, because the transfer is necessary to perform our agreement with you, or under a written agreement that requires the recipient to give your information a level of protection substantially similar to POPIA.

8. How we protect your information

• All traffic between the app and our servers is encrypted in transit using TLS.
• Access to your account requires authentication, and access to health information requires that your identity has been verified.
• Access by our staff and by healthcare practitioners is limited to those who need it to do their work.
• We keep our systems and dependencies patched, and we review our security arrangements periodically.

No system is completely secure. We will notify you and the Information Regulator of a compromise of your personal information where POPIA requires us to.

9. How long we keep your information

10. Deleting your account

You can delete your Guud Passport account at any time, from inside the app, under Settings → Account Settings → Account Deletion. You can also request deletion using our online form, which sets out exactly what is removed and what is kept.

11. Your rights

Under POPIA you have the right to:

• Be told what personal information we hold about you, and to be given a copy of it
• Ask us to correct or complete information that is inaccurate, misleading or out of date
• Ask us to delete or destroy information we no longer have grounds to keep
• Object to processing based on our legitimate interests, on reasonable grounds
• Withdraw consent where our processing relies on it
• Not be subject to a decision based solely on automated processing that significantly affects you
• Complain to the Information Regulator

To exercise any of these, contact our Information Officer at privacy@xtend.co. We may need to verify your identity first, precisely because the information at stake includes health information.

Complaints

12. Children

Guud Passport is provided to working adults through employer and programme arrangements. It is not intended for, and we do not knowingly create accounts for, anyone under 18. If you believe a child has an account, contact us and we will remove it.

13. Guud Passport is not an emergency service

Guud Passport does not provide emergency medical services, and the information in the app is not a substitute for professional medical advice, diagnosis or treatment. If you have a medical emergency, contact your local emergency services immediately.

14. Changes to this policy

We may update this policy as the app changes. When we do, we will update the date at the top of this page, and we will tell you in the app or by email if the change is significant.

15. Contact us