Privacy Policy - Anywhere M.D.

This Privacy Policy is considered an integral part of our Terms and Conditions, and applies to all services and websites owned and operated by AnywhereMD E-Consult and CVM Clinics and Surgicenter, Inc (hereafter referred to as “AnywhereMD E-Consult”, “AnywhereMD”, or ”E-Consult”), including https://anywheremd.ph/ and any other websites, pages, features, or content we own or operate, and to your use of the AnywhereMD E-Consult platform and any related Services. Our Privacy Policy is designed to help you better understand how we collect, use, store, process, and transfer your information when using our Services.

Please carefully review this Privacy Policy and our Terms and Conditions. By using our Services, you acknowledge all of the policies and procedures described in the foregoing documents. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy or our Terms and Conditions you should immediately discontinue use of our Services.

Key Definitions – Please note, some terms described in this Privacy Policy are also defined under our Terms and Conditions, for those that are not defined therein, please refer below for their definition:

Aggregate Information: information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.
De-identified Information: information that has been stripped of your Registration Information (e.g., your name and contact information), Personal Information, and other identifying data such that you cannot reasonably be identified as an individual, also known as pseudonymized information.
Personal Information: information that can be used to identify you, either alone or in combination with other information. AnywhereMD E-Consult collects and stores the following types of Personal Information.
- Registration Information: information you provide about yourself when registering for and/or purchasing our Services (e.g. name, email, address, user ID and password, and payment information)
- Self Reported Information, Health Information or Medical History: information regarding your health information, past and present and all medical history recorded within AnywhereMD E-Consult. This is information you provide directly to us, including your disease conditions, other health-related information, personal traits, ethnicity, family history, and other information that you enter into surveys, forms, or features while signed in to your AnywhereMD E-Consult account.
- Sensitive Information: information about your health and health history, genetic Information, and certain Self-Reported Information such as racial and ethnic origin, sexual orientation, and political affiliation.
- Professional Information: information about your credentials, license and capacity as a professional, particularly as a licensed physician under the territory of the Philippines.
User Content: all information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials – other than Personal Information generated by users of AnywhereMD E-Consult Services and transmitted, whether publicly or privately, to or through AnywhereMD E-Consult.
Web-Behavior Information: information on how you use AnywhereMD E-Consult’s Services collected through log files, cookies, web beacons, and similar technologies, (e.g., browser type, domains, page views).

Information we collect

Information you provide directly to us or to another party through us
- Registration Information. When you create an AnywhereMD E-Consult account, reach out and communicate to a patient or physician, or when you complete research surveys, post on our platform or use other messaging features, and when you contact Customer Care, we collect Personal Information, such as your name, date of birth, billing and shipping address, payment information (e.g., credit card) and contact information (e.g. email, phone number and license number).
- Self-Reported Information, Health Information or Medical History. You have the option to provide us with additional information about yourself through surveys, forms, features and applications. For example, you may provide us with information about your personal traits (e.g., eye color, height), ethnicity, disease conditions (e.g. Type 2 Diabetes), other health-related information (e.g. pulse rate, cholesterol levels, visual acuity), and family history information (e.g. information similar to the foregoing about your family members). Before you disclose information about a family member, you should make sure you have permission from the family member to do so.
- Professional Information. If you are a physician using our platform, we may collect information about your credentials, license and capacity as a professional, particularly as a licensed physician under the territory of the Philippines.
- User Content. Some of our Services allow you to create and post or upload content, such as data, text, software, music, audio, photographs, graphics, video, messages, or other materials that you create or provide to us through either a public or private transmission (“User Content”). For example, User Content includes any discussions, posts, or messages you send on AnywhereMD E-Consult’s Forums.
- Blogs and Forums. Our website may offer publicly accessible blogs. Additionally, AnywhereMD E-Consult users may participate in our online Forums. You should be aware that any information you provide or post in these areas may be read, collected, and used by others who access them. To request that we remove or de-identify your Personal Information from our blog or Forums, contact us through Customer Care. Please note that whenever you post something publicly, it may sometimes be impossible to remove all instances of the posted information, for example, if someone has taken a screenshot of your posting. Please exercise caution before choosing to share Personal Information publicly on our blogs, Forums or in any other posting. You may be required to register with a third party application to post a comment. To learn how the third party application uses your information, please review the third party’s Privacy Policy.
- Social media features and widgets. Our Services may include Social Media Features, such as the Facebook “Like” or “Share” button and widgets (“Features”). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. They may also allow third-party social media services to provide us information about you, including your name, email address, and other contact information. The information we receive is dependent upon your privacy settings with the social network. Features are either hosted by a third-party or hosted directly on our site. Your interactions with these Features are governed by the Privacy Policies of the third party companies providing them. You should always review and, if necessary, adjust your privacy settings on third party websites and services before linking or connecting them to our website or Service.
- Third party services (e.g., social media and third party videoconference, teleconference and chat applications). If you use a third party site, such as Facebook or Twitter, in connection with our Services to communicate with another person (e.g., to make or post referrals or to request that we communicate with another person), then in addition to that person’s name and contact information, we may also collect other information (e.g., your profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers) depending on your privacy settings on the third party site. We do not control the third party site’s information practices, so please review the third party’s Privacy Policy and your settings on the third party’s site carefully.
- Referral information and sharing. There may be instances when you refer a person to AnywhereMD E-Consult or choose to ask us to share your AnywhereMD E-Consult results with your selected physician or another patient or user. In these instances, AnywhereMD E-Consult may ask for that person’s email address from you. We will use their email address solely, as applicable, to make the referral or to communicate your sharing request to them, and we will let your contact know that you requested the communication. By participating in a referral program or by choosing to share information with another person, you confirm that the person has given you consent for AnywhereMD E-Consult to communicate (e.g., via email) with him or her. The person you referred may contact us through Customer Care to request that we remove this information from our database.
- Customer service. When you contact Customer Care or correspond with us about our Service, we collect information to: track and respond to your inquiry; investigate any breach of our Terms and Conditions, Privacy Policy or applicable laws or regulations; and analyze and improve our Services.
Web-Behavior Information collected through tracking technology (e.g. from cookies and similar technologies).
- We, and our third party service providers use cookies and similar technologies (such as web beacons, tags, scripts and device identifiers) to:
  - help us recognize you when you use our Services;
  - customize and improve your experience;
  - provide security;
  - analyze usage of our Services (such as to analyze your interactions with the results, reports, and other features of the Service);
  - gather demographic information about our user base;
  - offer our Services to you;
  - monitor the success of marketing programs; and
  - serve targeted advertising on our site and on other sites around the Internet.
Cookies.
- Our website uses cookies. For more information about cookies please see our Cookie policy.
- If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. For more information, including the types of cookies found on AnywhereMD E-Consult and how to control cookies, please read our Cookie Policy.
Google Analytics or any similar Analytics platform.
- Google Analytics or an analogous platform is used to perform many of the tasks listed above. We use the User-ID feature of Google Analytics to combine behavioral information across devices and sessions (including authenticated and unauthenticated sessions). We have enabled the following Google Analytics Advertising features: Remarketing, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and DoubleClick Campaign Manager integration. We do not merge information collected through any Google advertising product with individual-level information collected elsewhere by our Service. Learn more about how Google collects and uses data here. To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link.
Other Types of Information.
- We continuously work to enhance our Services with new products, applications and features that may result in the collection of new and different types of information. We will update our Privacy Policy and/or obtain your prior consent to new processing, as needed.

How we use your information

AnywhereMD E-Consult will use and share your Personal Information with third parties only in the ways that are described in this Privacy Policy.
- To provide you with Services and analyze and improve our Services. We use the information described above to operate, provide, analyze and improve our Services. These activities may include, among other things, using your information in a manner consistent with this Privacy Policy to:
  - open your account, enable purchases and process payments, communicate with you, and implement your requests (e.g., referrals);
  - Provide counter parties, third parties, other users of AnywhereMD E-Consult (whether patient or physician) access to relevant and important Information necessary to the provision of teleconsultation services and other related services;
  - enable and enhance your use of our website and mobile application(s), including authenticating your visits, providing personalized content and information, and tracking your usage of our Services;
  - contact you about your account, and any relevant information about our Services (e.g. policy changes, security updates or issues, etc.);
  - enforce our Terms and Conditions and other agreements;
  - monitor, detect, investigate and prevent prohibited or illegal behaviors on our Services, to combat spam and other security risks; and
  - perform research & development activities, which may include, for example, conducting data analysis and research in order to develop new or improve existing products and services, and performing quality control activities.
- To allow you to share your Personal Information for Statistical, Medical, Business and Marketing Research and Scientific Progress. When you become a user of AnywhereMD E-Consult and by using its Services you participate in medical, business and marketing research and scientific progress, and AnywhereMD E-Consult, its researchers, and its partners, contractors, successors and assignees can include your de-identified Health Information, Medical History, and Self-Reported Information, or Professional Information as the case may be, in a large pool of user data for analyses aimed at making statistical, marketing, business, and medical discoveries and developments (“AnywhereMD E-Consult Research”). AnywhereMD E-Consult Research may be sponsored by, conducted on behalf of, or in collaboration with third parties, such as non-profit foundations, academic institutions or pharmaceutical companies. AnywhereMD E-Consult Research may study a specific group or population, identify potential areas or targets for therapeutics development, conduct or support the development of drugs, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on medical research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve health care.
- To provide customer support. When you contact Customer Care, we may use or request Personal Information, including Sensitive Information, as necessary to answer your questions, resolve disputes, and/or investigate and troubleshoot problems or complaints. In some instances, we may be required to process one user’s Personal Information to resolve another user’s dispute or request. For example, if a user reports behavior that violates our Terms and Conditions, we will separately process both users’ Personal Information and respond separately to each individual as appropriate. We will not share your Personal Information with another user without your consent.
- To conduct surveys or polls, and obtain testimonials. We value your feedback and may send you surveys, polls, or requests for testimonials to improve and optimize our Services. You are in control of the information you would like to share with us. If you do not wish to receive these requests, you can manage them in your Account Settings.
- To provide you with marketing communications. By creating an AnywhereMD E-Consult account, you are agreeing that we may send you product and promotional emails or notifications about our Services, and offers on new products, services, promotions or contests. You can unsubscribe from receiving these marketing communications at any time. To unsubscribe, click the email footer “unsubscribe” link. You may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.

Information we share with third parties and other users

Other Users. We share your Information to other users with your consent in order to allow for teleconsultation service and other related services to be provided in a sufficient manner in AnywhereMD E-Consult. If you are a Patient User, we may share your Information to your selected Physician Users in order to provide them access to relevant and important information to provide the Services of AnywhereMD E-Consult. If you are a Physician User, we may share your Information to a Patient User or publicly in a roster of physicians available in order to allow our Patient Users access to information relevant to their selection of physician for teleconsultation service or any other relevant service.
General service providers. We share the information described above with our third party service providers, partners and contractors (“Service Providers”) as necessary for them to provide their services to us and help us perform our contract with you. Service providers are third parties (other companies or individuals) that help us to provide, analyze and improve our Services. AnywhereMD E-Consult engages third party service providers to assist in supporting and allowing us to provide our Services, including in the following areas:
- Payment Processing. Our payment processor processes certain Registration Information, such as your billing address and credit card information, as necessary to enable you as to pay for purchase an AnywhereMD E-Consult Service, or receive payment for your service if you are a physician user.
- Customer Care support. Our Customer Care team uses a number of tools to help organize and manage the requests we receive. These tools help to ensure we provide timely, high quality support.
- Cloud storage, IT, and Security. Our cloud storage providers provide secure storage for information in AnywhereMD E-Consult databases, ensure that our infrastructure can support continued use of our Services by AnywhereMD E-Consult customers, and protect data in the event of a natural disaster or other disruption to the Service. Our IT and security providers assist with intrusion detection and prevention measures to stop any potential attacks against our networks.
- Marketing and analytics. When you use our Services, including our website, our third party service providers may collect Web-Behavior Information about your visit, such as the links you clicked on, the duration of your visit, and the URLs you visited. This information can help us improve site navigability and assess our Marketing campaigns. Per applicable data protection regulations, we present visitors with a cookie opt in to allow the processing described above via Functionality and Advertising Cookies.
“Targeted advertising” service providers. We permit third party advertising networks and providers to collect Web-Behavior Information regarding the use of our Services to help us to deliver targeted online advertisements (“ads”) to you. They use cookies and similar technologies, to gather information about your browser’s or device’s visits and usage patterns on our Services and on other websites over time, which helps to better personalize ads to match your interests, and to measure the effectiveness of ad campaigns. For more information about our marketing practices, please review our Cookie Policy.
Aggregate information. We may share Aggregate Information, which is information that has been stripped of your name and contact information and combined with information of others so that you cannot reasonably be identified as an individual, with third parties.
Information we share with commonly owned entities. We may share some or all of your Personal Information with other companies under common ownership or control of AnywhereMD E-Consult, which may include our subsidiaries, our corporate parent, or any other subsidiaries owned by our corporate parent in order to provide you better service and improve user experience. Generally, sharing such information is necessary for us to perform on our contract with you. We may provide additional notice and ask for your prior consent if we wish to share your Personal Information with our commonly owned entities in a materially different way than discussed in this Privacy Policy.
As required by law. Under certain circumstances your Personal Information may be subject to processing pursuant to laws, regulations, judicial or other government subpoenas, warrants, or orders. For example, we may be required to disclose Personal Information in coordination with regulatory authorities in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. AnywhereMD E-Consult will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that AnywhereMD E-Consult may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the AnywhereMD E-Consult Terms and Conditions and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of AnywhereMD E-Consult, its employees, its users, its clients, and the public.
Business transaction. In the event that AnywhereMD E-Consult goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets your Personal Information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Policy.

Your choices

Access to your account. We provide access to your AnywhereMD E-Consult data within your AnywhereMD E-Consult account. You can access and download data processed by AnywhereMD E-Consult within your Account Settings and within applicable Reports, Tools, and features. If you lose access to your AnywhereMD E-Consult account or account email address, please contact Customer Care for assistance. If you lose access to your AnywhereMD E-Consult account, in certain circumstances, we may require that you submit additional information sufficient to verify your identity before providing access or otherwise releasing information to you. If you choose not to submit the required documentation, or the information provided is not sufficient for the purposes sought, AnywhereMD E-Consult will not be able to sufficiently verify your identity in order to complete your request. You may access, correct or update most of your Registration Information on your own within your Account Settings. You may be able to correct Self-Reported Information entered into a survey, form, or feature within your account, such as on the surveys page, by clicking “Edit your answers here.” Please note that you may not be able to delete User Content that has been shared with others through the Service and that you may not be able to delete information that has been shared with third parties.
Marketing communications. As noted earlier, you may be asked to opt-in to receive product and promotional emails or notifications when creating your AnywhereMD E-Consult account depending on where you are located. Otherwise, you may view or update your email notification preferences by contacting our Privacy Administrator at [email protected]. You can also click the “unsubscribe” button at the bottom of promotional email communications.
Sharing outside of the AnywhereMD E-Consult Services. You may decide to share your Personal Information with friends and/or family members, doctors or other health care professionals, and/or other individuals outside of our Services, including through third party services such as social networks and third party apps that connect to our website and mobile apps through our application programming interface (“API”). These third parties may use your Personal Information differently than we do under this Privacy Policy. Please make such choices carefully and review the Privacy Policys of all other third parties involved in the transaction. AnywhereMD E-Consult does not endorse or sponsor any API applications, and does not affirm the accuracy or validity of any interpretations made by third party API applications. In general, it can be difficult to contain or retrieve Personal Information once it has been shared or disclosed. AnywhereMD E-Consult will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information with others.
Account deletion. If you no longer wish to participate in our Services, or no longer wish to have your Personal Information be processed, you may delete your AnywhereMD E-Consult account and Personal Information within your Account Settings. Once you submit your request, we will send an email to the email address linked to your AnywhereMD E-Consult account detailing our account deletion policy and requesting that you to confirm your deletion request. Once you confirm your request to delete your account and data, your account will no longer be accessible while we process your request. Once you confirm your request, this process cannot be cancelled, undone, withdrawn, or reversed. When your account is deleted, all associated Personal Information is deleted, subject to the following limitations:

Information previously included in AnywhereMD E-Consult Research. As stated in any agreement or consent you have agreed to including our Terms and Conditions, this Privacy Policy and Consent to Teleconsulting, Personal Information and/or Self-Reported Information that you have previously provided and for which you have given consent to use in AnywhereMD E-Consult Research cannot be removed from completed studies that use that information, and your de-identified data may still be, used in future AnywhereMD E-Consult Research.
Legal Retention Requirements. AnywhereMD E-Consult will also retain limited information related to your account and data deletion request, including but not limited to, your email address, account deletion request identifier, and record of legal agreements for a limited period of time as required by contractual obligations, and/or as necessary for the establishment, exercise or defense of legal claims and for audit and compliance purposes.

Security measures

AnywhereMD E-Consult takes serious care of the trust you place in us. AnywhereMD E-Consult implements physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your Personal Information.
AnywhereMD E-Consult produces secure applications by design. AnywhereMD E-Consult incorporates explicit security reviews in the software development lifecycle, quality assurance testing and operational deployment.
De-identification/Pseudonymization. Registration Information is stripped from Sensitive Information, including all Health Information, Medical History and Self-Reported Information, and Professional Information as the case may be. This data is then assigned a randomly generated ID so an individual cannot reasonably be identified.
Encryption. AnywhereMD E-Consult uses industry standard security measures to encrypt Sensitive Information both at rest and in transit.
Separation of Environments. AnywhereMD E-Consult ensures processing, production, and research environments are separated and access is restricted. Data, including Registration Information, Personal Information, and Self-Reported Information are segmented across logical database systems to further prevent re-identifiability.
Limiting access to essential personnel. We limit access to Personal Information to authorized personnel, based on job function and role. AnywhereMD E-Consult access controls include multi-factor authentication, single sign-on, and strict least-privileged authorization policy.
Detecting threats and managing vulnerabilities. AnywhereMD E-Consult uses digital technology for intrusion detection and prevention measures to stop any potential attacks against its networks.
Incident Management. AnywhereMD E-Consult maintains a formal incident management program designed to ensure the secure, continuous delivery of its Services, and complies with the data breach reporting standards required under the Data Privacy Act of 2012 (RA 10173). AnywhereMD E-Consult has also implemented an incident management program using industry best practices.
Managing third party service providers. AnywhereMD E-Consult requires service providers to implement and maintain accepted industry standard administrative, physical and technical safeguards to protect Personal Information.
Your Responsibility. Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify AnywhereMD E-Consult of any unauthorized use of your password. AnywhereMD E-Consult cannot secure Personal Information that you release on your own or that you request us to release.

Recording of Proceedings of Teleconsultation Services

AnywhereMD E-Consult strictly prohibits and does not condone audio, video or transcript recording. This is done to respect the privacy of all user and owners of Information in AnywhereMD E-Consult. However, such audio, video or transcript recording may done in the following instances:
- The written consent is provided by all owners of Information, whether patient or physician user, or a third party, as well as AnywhereMD E-Consult.
- When legally required by the law of the relevant jurisdiction or through a proper judicial order.

Storage of Information

AnywhereMD E-Consult reserves 1 gb/year of storage for each user to maintain the Information as accessible and to allow the Services to occur, and for the Terms and Conditions and Privacy Policy to be enforced. Physician users may delete data on his account to make space for new information or open up storage space. The Physician user may download a secure copy of his account data for personal safekeeping as prescribed by law before deleting such data from AnywhereMD server. Alternatively, the user MD may avail of additional storage space from AnywhereMD at an additional cost to the user MD. The Patient and Physician Users are not allowed to modify any information submitted or saved to AnywhereMD servers .Such information includes but is not limited to the following; chief complaint, history, signs and symptoms, physical examination findings, diagnosis, plan of action, etc. It is the responsibility of the Patient and Physician User to ensure that all information and data are correct.
All users are cautioned of the above, and are encouraged to save the necessary information in their own capacity independent of AnywhereMD E-Consult. AnywhereMD E-Consult makes no guarantee and has no duty to store Personal Information or any Information whatsoever of the users, except as required by Philippine Law.

Linked websites

AnywhereMD E-Consult provides links to third party websites operated by organizations not affiliated with AnywhereMD E-Consult. AnywhereMD E-Consult does not disclose your information to organizations operating such linked third party websites. AnywhereMD E-Consult does not review or endorse, and is not responsible for the privacy practices of these organizations. We encourage you to read the Privacy Policies of each and every website that you visit. This Privacy Policy applies solely to information collected by AnywhereMD E-Consult and our service providers on our behalf.

Information on Data Privacy Rights under the Data Privacy Act of 2012 (RA 10173)

Our relationship with you. We are the “controller” with respect to your Personal Information because we determine the means and purposes of processing your information when using our Services.
Legal bases for processing Personal Information from the Philippines. We describe how we process your Personal Information in this Privacy Policy. We may process your Personal Information if you consent to the processing, to satisfy our legal obligations, if it is necessary to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, rights or safety of AnywhereMD E-Consult, our customers or others.
Direct Marketing. We will obtain your consent where required to send you marketing communications using electronic means. You may withdraw your consent at any time by notifying us through our contact information and Customer Care. We will only contact you by electronic means (email, push notification, SMS, etc.) with information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.
We will only share your Personal Information with third parties for marketing purposes with your explicit consent. If you do not want us to use your Personal Information in this way, please contact us through Customer Care. You may raise such objection with regard to initial or further processing for purposes of direct marketing at any time and free of charge. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.
Other marketing activities will happen based on the legitimate interests of AnywhereMD E-Consult. E.g., where we tailor marketing communications or send targeted marketing messages via post, phone or social media and other third party platforms; and in providing existing customers with information (via email or other channels) about similar products and services.
Privacy Rights. You can exercise your privacy rights by following the instructions below or contacting us at [email protected]. We will handle your request under applicable law. When you make a request, we may verify your identity to protect your privacy and security.
- Right to withdraw consent. To the extent AnywhereMD E-Consult requests and you provide your consent to the processing of your Personal Information, you can withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.
- Right of access to and rectification of your Personal Information. Our site allows you to access and rectify certain Registration Information within your Account Settings, and your Self-Reported Information by going to the surveys page. If you would like to access or rectify any other information, contact Customer Care and we will do our best to assist you without undue delay. We may reject part or all of your request if responding to your request could adversely affect the rights and freedoms of others.
- Right to erasure (or, “Right to be Forgotten”). As explained under our provisions on Account Deletion, we allow our customers to delete their accounts at any time. You can request erasure of Personal Information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing to which you previously consented, but later withdrew such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. If we have made your Personal Information public and we are required to erase such Personal Information, we will take reasonable steps, including technical measures, to inform controllers that are processing any links to or copies or replications of your Personal Information of your erasure request. Our assistance with your request for erasure is subject to limitations by relevant data protection laws, available technology and the cost of implementation.
- Right to Data Portability. If we process your Personal Information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your Personal Information in a structured, commonly used and machine-readable format, and to have us transfer your Personal Information directly to another controller, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your Personal Information.
- Right to restriction of our processing. You can restrict our processing of your Personal Information where one of the following applies: (a) you dispute the accuracy of Personal Information processed by AnywhereMD E-Consult (for a period enabling us to verify its accuracy); (b) the processing is unlawful and you oppose the erasure of the Personal Information and request the restriction of its use instead; (c) AnywhereMD E-Consult no longer needs the Personal Information for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims; and (d) you have objected to certain processing relying on legitimate interest, pending the verification whether AnywhereMD E-Consult’s legitimate grounds override your rights. Restricted Personal Information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will notify you if the restriction is lifted.
- Notification of erasure, rectification and restriction. We will provide notice to each recipient that we disclosed your Personal Information to regarding any rectification or erasure of Personal Information or restriction of processing, unless you initiated the disclosure, we have previously made a statement that we will not provide prior notice, or providing notice proves impossible or involves disproportionate effort. Upon your request, we will share the list of recipients with you.
- Right to object to processing. Where the processing of your Personal Information is based on consent, contract, or legitimate interests described under the Legal Bases for Processing heading above, you may restrict or object, at any time, to the processing of your Personal Information as permitted by applicable law. We may continue to process your Personal Information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
- Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you, except as allowed under applicable data protection laws.
- Retention of your Personal Information. Unless you make a request for us to delete your account or delete certain Personal Information (i.e., User Content, etc.), or unless we have indicated otherwise, or you have previously agreed to a different data retention period, we will store your Personal Information as long as your account is open. If you request to delete your account, we will take the steps described under “Your Choices – Account Deletion” and delete all your Personal Information, unless a longer retention period is required or permitted by law.
- The rights described above may be limited by local laws depending on the applicable jurisdiction. Further, your right of access and deletion is not absolute and may not be available if fulfillment of such right would, among other things:
  - cause interference with execution and enforcement of the law and legal private rights (such as in the case of the investigation or detection of legal claims or the right to a fair trial);
  - breach or prejudice the rights of confidentiality and security of others;
  - prejudice security or grievance investigations, corporate reorganizations, future and ongoing negotiations with third parties, the compliance with regulatory requirements relating to economic and financial management; or
  - otherwise violate the interests of others or where the burden or cost of providing access would be disproportionate.
Complaints. If you believe that we have infringed your rights, we encourage you to contact us so that we can try to address your concerns or dispute informally. Our contact information is:
Dr. Aragon Belza
Privacy Policy Officer
[email protected]

Changes to this Privacy Policy

Whenever this Privacy Policy is changed in a material way, a notice will be posted as part of this Privacy Policy and on our website for 30 days. After 30 days the changes will become effective. In addition, all customers will receive an email with notification of the changes prior to the change becoming effective. AnywhereMD E-Consult may provide additional “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. Such notices may supplement or clarify AnywhereMD E-Consult’s privacy practices or may provide you with additional choices about how AnywhereMD E-Consult processes your Personal Information.

Contact Information

If you have questions about this Privacy Policy, or wish to submit a complaint, please email AnywhereMD E-Consult at:
Dr. Aragon Belza
Privacy Policy Officer
[email protected]