INTRODUCTION

ALLWELL HOME HEALTHCARE L.L.C., operating under the brand name “Vervé Wellness” (“Vervé”, “we”, “us” or “our”), operates this website, including its content, features, products and services (collectively, the “Services”).

This Privacy Policy describes how we collect, use, process and disclose your Personal Data when you visit, use or make a purchase or other transaction through the Services, use our healthcare or wellness services, or otherwise communicate with us.

For the purposes of this Privacy Policy, “Personal Data” means information that identifies or can reasonably be linked to you. Certain information relating to your health, medical condition, genetic information or healthcare services may constitute Sensitive Personal Data under applicable UAE law.

This Privacy Policy explains how we process your Personal Data. Where your consent is required by applicable law, we will obtain it separately through an appropriate consent mechanism. 

PERSONAL DATA WE COLLECT 

Depending on how you interact with our Services, we may collect or process:

• Contact Information:  including your name, address, telephone number and email address.
• Account Information, including your username, password, preferences and settings, where applicable.
• Healthcare Information:  including medical history, health conditions, symptoms, medications, allergies, consultations, treatments, healthcare assessments and other information necessary to provide our healthcare and wellness Services.
• Diagnostic and Genetic Information: including laboratory results, diagnostic reports, biomarkers, screening results and genetic information, where applicable to the Services you use.
• Transaction Information, including products or Services viewed or purchased, appointments, orders, payment information and transaction history.
• Communications: including information you provide when you contact us, communicate with healthcare professionals, request support, submit an enquiry or provide feedback.
• Device and Usage Information: including your IP address, browser and device information, network information, identifiers and information regarding how you interact with our Website and Services.

We will process Sensitive Personal Data only where permitted or required under applicable law and for specified and lawful purposes.

SOURCES OF PERSONAL DATA

We may collect Personal Data from the following sources:

• Directly from you: including when you create an account, use our Services, book an appointment, make a purchase, communicate with us or otherwise provide information; 
• Automatically through the Services:  including from your device and through cookies and similar technologies; 
• From healthcare professionals, laboratories, service providers and other third parties: where such collection is permitted by applicable law and necessary for the provision or administration of the Services.
• From our partners or other third parties: where permitted by applicable law.

HOW WE USE YOUR PERSONAL DATA

Depending on how you interact with us or which Services you use, we may use your Personal Data for the following purposes:

• Providing and Improving the Services: To provide healthcare, wellness and other Services, process purchases and payments, manage appointments and accounts, maintain records, provide customer support and improve our Services.
• Healthcare and Treatment: To facilitate consultations, assessments, diagnostic testing, treatments, healthcare programmes and related services, including communicating relevant information to healthcare professionals and service providers involved in your care.
• Marketing and Communications: To send you information about our Services, products, offers and promotions, where permitted by law and in accordance with your communication preferences.
• Security and Fraud Prevention: To protect our Website and Services, authenticate accounts, prevent fraud or misuse, and maintain the security of our systems and users.
• Legal and Regulatory Reasons: To comply with applicable laws, regulations and legal processes, respond to lawful requests from competent authorities, enforce our terms and policies, and protect our rights, users and Services.

LEGAL BASIS FOR PROCESSING 

We process Personal Data on a lawful basis under applicable UAE law.

Depending on the circumstances, processing may be based on your consent, the performance of a contract or steps requested by you, compliance with a legal or regulatory obligation, protection of your interests, or other circumstances in which processing is permitted without consent under applicable law.

This may include processing necessary for medical diagnosis, healthcare, treatment, health or social care, health insurance, management of healthcare services, public health or other purposes permitted under UAE law.

Where consent is required, we will obtain it through a clear affirmative action and will not treat consent as having been given merely by your silence or inactivity.

HOW WE DISCLOSE PERSONAL DATA

In certain circumstances, we may disclose your Personal Data to third parties for legitimate purposes and as permitted or required by applicable law. Such circumstances may include:

• Service Providers: With healthcare professionals, laboratories, technology providers, payment processors, IT providers, cloud service providers, delivery partners, customer support providers and other vendors who provide services on our behalf. 
• Healthcare and Service Partners: With healthcare providers, diagnostic laboratories and other partners involved in providing or administering the Services to you, where necessary and permitted by law. 
• At Your Direction: Where you expressly request or authorise the disclosure, or where disclosure is otherwise permitted or required by applicable law
• Affiliates: With our affiliates or entities within our corporate group, where applicable. 
• Legal and Business Transactions: Where necessary in connection with a merger, acquisition, restructuring, sale of assets or similar business transaction, or to comply with applicable law, legal process or requests from competent authorities, enforce our terms and policies, or protect our rights, users and Services. 

We require third parties that process Personal Data on our behalf to handle such information in accordance with applicable law and appropriate confidentiality and security requirements.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies to maintain and improve the quality, security and functionality of our Services, remember your preferences, understand how our Website is used, and support our marketing and advertising activities.

Some cookies may be placed by third-party service providers that assist us with analytics, advertising, payment processing or other Website functionality.

You can manage or disable cookies through your browser settings. However, disabling certain cookies may affect the functionality of the Website.

Where required by applicable law, we will obtain your consent before placing non-essential cookies or similar technologies on your device.

Where third parties process Personal Data on our behalf, we will require them to process it only for authorised purposes and subject to appropriate contractual, confidentiality, security and data-protection obligation.

DATA RETENTION

We retain your Personal Data only for as long as reasonably necessary to provide our Services, fulfil the purposes described in this Privacy Policy, comply with applicable legal and regulatory requirements, resolve disputes, enforce our agreements, and protect our rights.

The retention period may vary depending on the type of Personal Data and the purpose for which it was collected. Healthcare and medical records may be retained for longer periods where required by applicable healthcare laws, regulations or professional requirements.

When Personal Data is no longer required, we will delete, anonymise or securely dispose of it in accordance with applicable law and our internal retention practices.

DATA SECURITY

We take reasonable technical and organisational measures to protect your Personal Data against unauthorised access, disclosure, alteration, loss, misuse or destruction.

However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee the absolute security of your Personal Data.

If we become aware of a Personal Data breach affecting your information, we will take appropriate steps to investigate, mitigate and respond to the breach and make any notifications required under applicable law.

YOUR PRIVACY RIGHTS

Subject to applicable law, you may have certain rights in relation to your Personal Data, including the right to:

• request access to the Personal Data we hold about you; 
• request correction or updating of inaccurate or incomplete Personal Data; 
• request deletion of your Personal Data where permitted by law; 
• request restriction of certain processing; 
• object to certain processing, where applicable; 
• withdraw consent where processing is based on your consent; and 
• request a copy of your Personal Data where a right to data portability applies. 

You may also request information about the categories of Personal Data we process, purposes of processing, recipients or categories of recipients, applicable retention periods and relevant cross-border safeguards.

Where we use automated processing or profiling that produces decisions with legal or similarly significant effects, we will provide the rights and safeguards required under applicable law, including human review where required

Certain rights may be subject to applicable legal, regulatory or healthcare-record retention requirements. We may also need to verify your identity before responding to a request.

To exercise your rights or make a privacy-related request, please contact us using the details provided in the Contact Us section below.

CHILDREN’S PRIVACY

Our online Services are not generally directed to children. Where we provide healthcare Services to a child, we will process the child's Personal Data in accordance with applicable healthcare and data protection requirements and any required parental/guardian authorisation.

If you believe that a child has provided Personal Datto us without appropriate authorisation, please contact us so that we can take appropriate steps to address the matter.

THIRD-PARTY WEBSITES AND SERVICES

Our Website or Services may contain links to websites, applications or services operated by third parties. We are not responsible for the privacy practices, content or security of such third parties.

We encourage you to review the privacy policies of any third-party websites or services before providing them with your Personal Data.

Our Services may also use third-party platforms and service providers to support functions such as payments, analytics, communications, hosting and other services. Their processing of Personal Data may be subject to their own privacy policies and applicable terms.

INTERNATIONAL DATA TRANSFERS

Your Personal Data may be processed or stored in the United Arab Emirates or in other countries where we or our service providers operate.

Where Personal Data is transferred outside the UAE, we will take appropriate steps to ensure that such transfer and processing is carried out in accordance with applicable UAE data protection and healthcare laws.

This may include transfers to third-party technology, cloud, payment, laboratory, analytics or other service providers where necessary to provide or support our Services.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our Services, our practices, or applicable legal and regulatory requirements.

When we make changes, we will update the “Last Updated” date at the beginning of this Privacy Policy. Where required by applicable law, we will provide additional notice or obtain your consent to material changes.

We encourage you to review this Privacy Policy periodically to stay informed about how we handle your Personal Data.

CONTACT US

If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or have a concern regarding our handling of your Personal Data, you may contact us at:

ALLWELL HOME HEALTHCARE L.L.C.

Trading as: Vervé Wellness

Address: Office 1612, Park Lane, Business Bay, Dubai, United Arab Emirates
Email: info@vervewellness.ae

We will review and respond to privacy-related requests in accordance with applicable 

COMPLAINTS

If you have any concerns or complaints regarding our collection, use, processing or protection of your Personal Data, please contact us using the contact details provided in this Privacy Policy.

We will review and address your complaint in accordance with applicable law and our internal procedures.

You may also have the right to lodge a complaint with the relevant competent data protection or regulatory authority where permitted under applicable law.

CONSENT AND WITHDRAWAL OF CONSENT

Where we rely on your consent to process your Personal Data, you may withdraw your consent at any time, subject to applicable law and any consequences of such withdrawal.

Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

Please note that certain Personal Data may need to be retained or processed where required or permitted by applicable law, including for healthcare, regulatory, legal or record-keeping purposes.