1. General
KMS ETH Health Share Company provides the Tenawo Application, a set of tools and applications for people
that connect
healthcare providers with clients to improve their quality of life. The Tenawo Application consists of
the digital
Platform, the Tenawo Mobile Application and the Tenawo Dashboard (each as defined hereinafter and
collectively the
"Application").
The Platform is the engine of the Application and interacts with and transmits data between the Mobile
Application and
Dashboard. In addition, the Platform also analyses and stores data. The Dashboard is an online tool with
the sole
intention to display, add and store your data.
The Mobile Application interacts with third-party and the user to capture, analyze and display data and
forward it to
the Platform. The Results (as defined hereinafter) are automatically transferred to the Dashboard
through the Platform.
Tenawo ("Tenawo "we", "us") recognizes and understands the importance of the privacy of its users
("users", "You") and
wants to respect their desire to store and access personal information in a private and secure manner.
This Privacy Policy applies to our Application and our Website (collectively the "Products") and
describes how Tenawo
manages, stores and utilizes your Personal Data through its Products.
In order to use our Products, we require you to consent to the collection and processing of your
Personal Data before
you start using the Products. If you do not agree with the terms of this Privacy Policy, you may not use
in any manner
the Products.
Tenawo is committed to protecting the privacy of all of its users Personal Data and providing a secure,
user-controlled
environment for the use of the Products in accordance with the Privacy. At the same time, you also share
responsibility
for maintaining privacy and security for example, by not allowing any third party to use your personal
account on the
Tenawo Mobile Application and D Tenawo dashboard. Tenawo asks all users to be responsible for
safeguarding any
authentication information and to immediately notify Tenawo of any unauthorized use of your personal
Account. Please
read this Privacy Policy carefully (which is also available on our Website: www.tenawo.com ) so that you
fully
understand how we obtain and process your Personal Data. By accepting this Privacy Policy, you
acknowledge and agree
that you were adequately informed of the functioning and objectives of the Application
2. Definitions
"Account" means your account
registered through the
registration
process on the Tenawo Mobile Application or Tenawo
Dashboard.
"Application" means the (i) Tenawo
Platform; (ii)
Tenawo
Mobile Application and (iii) Tenawo Dashboard.
"Tenawo Dashboard" means the dashboard made available to the users, located at
www.tenawo.com
"Tenawo Mobile Application" means the mobile application (i) which the user has
to download on
its mobile device and
(ii) is intended to record (via third-party headsets and user input), display, analyze,
store and transmit your
epilepsy data.
“Tenawo Platform" means the platform on which the Tenawo Mobile Application and
the Tenawo
Dashboard are connected and
collectively function. Depending on the user profile different application functions can be made
available.
"Products" means the Application, Website and Documentation.
"Results" means the raw data and the results of the analysis by the Tenawo
Platform of
data recorded by the User
through the Tenawo Mobile Application.
"Insights" means the data collected via the application and rendered in an
optimal way by the
Tenawo Platform through
the Tenawo Mobile Application and Tenawo Dashboard.
"Third Parties" means any natural or legal person or entity other than Tenawo.
"Website" means the website available at www.tenawo.com.
3. Information
We may collect several types of personal information from the users of our Products, and store it on
your mobile device
and/or our server such as:
Contact information (e.g. your name, postal address, e-mail address, and mobile or other telephone
number).
The profile data provided by you on your account such as your name and profile picture.
Information in helpdesk support inquiries.
Patient demographics such as date of birth and gender.
Information about your device, such as its model, unique device identifier and operating system version
Information collected by manual input by the Application, such as seizure onset, etc.
Payment information such as transaction identifiers and summary information that does not include credit
card or bank
account numbers (we do not collect or store financial account information).
Web behavior information such as information related to how the users use the Products (e.g. browser
type, domains, page
views) collected through cookies and other automated technology.
Hereinafter collectively "Personal Data". We shall store your Personal Data on our servers located in
Addis Ababa,
Ethiopia and out of Addis Ababa. We would like to draw your attention to the fact that Personal Data
consisting of
patient medical data is also protected by medical secrecy rules.
4. How do we use your Personal Data
Tenawo (i) collects, (ii) uses, (iii) maintains and (iv) may share your Personal Data provided by you or
collected by us
with its affiliates, parent companies or other related companies for all purposes necessary to ensure
the proper
functioning and operation of the User accounts and/or the proper functioning of the Products. These
purposes may include
(collectively the "Purpose"):
Creating and managing your Account to use the Application;
Providing information and allowing the Users access to the Products;
Diagnosing technical problems and managing technical support and processing inquiries concerning the
Products;
Contacting the Users by phone, email, text message or push notifications (if they are enabled) to (i)
verify your
account (ii) for information and operational purposes such as account management, instructions, alerts,
reminders,
customer service, system maintenance and others;
Contacting the Users to (i) communicate about, and organize your participation in market research or
(ii) obtaining
testimonials;
Commercializing the Application;
Performing data analyses (including anonymization and aggregation of Personal Data) and using and
sharing the resulting
data to third parties for commercialization purposes;
The operation, evaluation and improvement of the Products (including the development of additional
products and/or
services, enhancing and improving the current Products, analysis of our Products, quality control
activities and
performing internal business functions such as accounting and auditing);
Protecting against, identify and prevent fraud and other unlawful activity, claims and other
liabilities;
• Complying with and enforcing any applicable legal obligations with respect to our Terms of Use and
Privacy Policy.
Furthermore, you agree that Tenawo is free to access, retain, and disclose Personal Data in the
following events:
In order to be in compliance with any applicable legislation or regulations;
If a law enforcement authority or other government official requests so;
To enforce the Tenawo Terms of Use or Privacy Policy
The investigation of any suspected or actual fraudulent or illegal activity and
To protect your or our safety and/or rights.
By using the Application, you acknowledge and explicitly agree that we may disclose certain information
to providers
that build profiles to improve the diagnostic capabilities of the Application. We will not share your
information
without your permission.
If you connect your Tenawo account to a third-party device or service, you may be asked to share your
information with
that application. We will not share your information without your permission.
You furthermore understand and agree that the technical processing and transmission of the Products,
including your
Personal Data, may involve (i) transmissions over various networks; and (ii) modifications to conform
and adapt to
technical requirements of connecting networks, or devices .
5. Security
Tenawo shall take appropriate administrative, technical and organizational measures against unauthorized
or unlawful
processing of any Personal Data or its accidental loss, destruction or damage, access, disclosure or
use. Upon written
request, Tenawo can provide you with a list of people of Tenawo that may have access to your Personal
Data. These people
have entered into confidentiality agreements prior to having been granted access to your Personal Data.
In the event of
and following discovery or notification of a breach of the security of the Personal Data, or access by
an unauthorized
person, Tenawo is required by law to notify the user if the breach is likely to affect your privacy
6. Cookies
When using the Products, we may collect certain information by automated means, such as cookies (small
text files stored
in your browser) and similar technologies, including mobile application identifiers, to improve your
experience of the
Products, increase security, measure use and effectiveness of the Products, identify and resolve issues
and marketing
purposes. We may also use cookies and other automated means for purposes such as management our Products
and other
aspects of the commercialization of our business.
The information we collect in this manner includes IP address, browser characteristics, device
characteristics,
operating system version, information on actions taken on our Products (such as usage, activity logs an
click-through),
and dates and times of visits. Log data is deleted on a regular basis.
The information we collect in this manner includes IP address, browser characteristics, device
characteristics,
operating system version, information on actions taken on our Products (such as usage, activity logs an
click-through),
and dates and times of visits. Log data is deleted on a regular basis.
Third parties, such as Google analytics, may also use cookies to collect information about your
activities on our
Products to understand and continue improving the performance of our Products. Please check the relevant
third party
website for more information about their use of cookies. Where this site allows such cookies to be set
or you access
other websites from the Products using the links provided, the operators of these websites will use
cookies in
accordance with their own cookies policy, which may differ from ours.
7. Disclosure to Third Parties
In the event of full or partial merger with, or acquisition of all or part of, Tenawo we may transfer
your Personal Data
to a Third Party. In such event, Tenawo shall impose this Third Party to use any Personal Data strictly
consistent with
this Privacy Policy.
Other than as set out in this Privacy Policy, we shall not sell or otherwise disclose your Personal Data
to Third
Parties without obtaining your prior explicit consent unless this is necessary for the purposes set out
in this Privacy
Policy or unless we are required to do so by law.
We may also share Personal Data with Third Party service providers who help us to provide, understand,
commercialize and
improve our Products. We do not authorize these Third Party service providers to use or disclose your
Personal Data
except as strictly necessary to perform any services under our supervision or to comply with applicable
legislation. We
seek to provide any such Third Party service provider with only the Personal Data they need to perform
their specific
function.
In any event, such Third Party service providers shall be obliged to treat your Personal Data in
accordance with this
Privacy Policy. However, Tenawo cannot be held liable for any damages, whether direct or indirect, that
may result from
the misuse of your Personal Data by such Third Party service providers.
8. Your rights
Right of access: If you are concerned or have any questions about your Personal Data,
you have
the right to request access to the
Personal Data which we hold or process about you. We will then provide you with information about
the data that are
being processed and on the source of those data.
Right of rectification and right of erasure: You have the right to request us free of
charge to
correct, erase or block any inaccuracies in your Personal Data if
such Personal Data would be incomplete, inaccurate or processed unlawfully.
Right to not be subject to automated individual decision making:
You have the right to request us not to be subject to a decision based solely on automated processing,
including
profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to object to data processing:
Without prejudice to the termination provisions of the Terms of Use, you may withdraw at any time your
consent to the
processing of your Personal Data by Tenawo by permanently removing the Application and notifying us in
writing
thereafter tenawokms@gmail.com. Upon
receipt of this
notification, Tenawo shall promptly stop any
processing of your
Personal Data. You may also ask us to stop using your Personal Data for direct marketing purposes.
9. Data retention and deletion.
We may retain information regarding you and your use of the Products, including Personal Data, for as
long as reasonably
needed to provide you with the Products and the uses described in this Privacy Policy. Please note that
we retain your
Personal Data even if you temporarily stop using the Application until you permanently delete the
Application on your
mobile device and notify us thereof. Upon notification, we may retain and continue to use and disclosure
your Personal
Data to Third Parties exclusively on a fully anonymized basis.
10. Third Party websites or applications
You acknowledge and agree that certain content or services provided by Third Parties may be made
available to you
through the Products. You agree that such linked content or services may have their own privacy policies
for which
Tenawo cannot be held responsible. Tenawo does not in any way review or endorse the privacy practices of
such Third
Parties.
11. Updates or changes to our Privacy Policy
Occasionally, we may change or update this Privacy Policy to allow us to use or share your previously
collected Personal
Data for other purposes. If Tenawo would use your Personal Data in a manner materially different from
that stated at the
time of the collection, we will provide you with a notice on our Website and in our Tenawo Mobile
Application indicating
that the Privacy Policy has been changed or updated and request you to agree with the updated or changed
Privacy Policy.