Privacy Policy - Amma
Privacy Policy
Amma – The Virtual Pharmacist Assistant
Effective Date: 1st May 2025
Last Updated: N/A
1. DEFINITIONS
1.1 “Act” means the Data Protection Act, 2012
(Act 843) of the Republic of Ghana.
1.2 “Controller” means Aide Chemists Limited,
responsible for determining the purposes and means of processing Personal Data.
1.3 “Personal Data” means any information
relating to an identifiable natural person as defined under the Act.
1.4 “Processing” means any operation performed
on Personal Data, including collection, recording, storage, retrieval,
disclosure, and erasure.
1.5 “Service” means Amma, the Virtual
Pharmacist Assistant, provided by the Controller.
2. SCOPE AND APPLICATION
2.1 This Policy governs all Processing
activities by the Controller in relation to the Service.
2.2 This Policy applies to all Users who access
or interact with the Service, whether directly or through a third-party
platform.
3. PRINCIPLES OF DATA PROCESSING
3.1 The Controller shall adhere to the
principles of lawfulness, fairness, transparency, purpose limitation, data
minimization, accuracy, storage limitation, integrity, confidentiality, and
accountability as prescribed by the Act.
3.2 Personal Data shall only be Processed where
a valid legal basis exists under the Act.
4. LAWFUL BASIS FOR PROCESSING
4.1 Consent: Processing based on the User’s
explicit consent for one or more specified purposes.
4.2 Contractual Necessity: Processing necessary
for the performance of a contract to which the User is a party.
4.3 Legal Obligation: Processing necessary for
compliance with a legal obligation to which the Controller is subject.
4.4 Legitimate Interests: Processing necessary
for the legitimate interests pursued by the Controller, excluding fundamental
rights and freedoms of the User.
5. CATEGORIES OF PERSONAL DATA
5.1 Non-sensitive Personal Data: anonymized
identifiers, device metadata, usage logs.
5.2 User-Provided Data: health queries,
uploaded documents, feedback.
5.3 Special Categories of Personal Data:
sensitive health information provided voluntarily by the User, subject to
enhanced protection measures.
6. PURPOSES OF PROCESSING
6.1 To deliver and enhance the Quality of
Service, including AI training and feature improvement.
6.2 To comply with legal, regulatory, or
contractual obligations.
6.3 To safeguard the Service against fraud,
abuse, or security incidents.
6.4 To respond to User requests, inquiries, and
support needs.
7. DATA RETENTION AND ERASURE
7.1 Data Retention Periods:
(a)
Usage Logs and Anonymized Data: Retained for up to twelve (12) months.
(b)
Uploaded User Documents: Retained for a maximum of thirty (180) days unless
retention is required by law.
(c)
Special Categories Data: Retained only as necessary and with explicit consent.
7.2 The Controller shall implement procedures
to securely delete or anonymize Personal Data upon expiry of the retention
period.
8. USER RIGHTS
8.1 Right to Access: Users may obtain
confirmation of Processing and access to their Personal Data.
8.2 Right to Rectification: Users may request
correction of inaccurate or incomplete Personal Data.
8.3 Right to Erasure: Users may request
deletion of Personal Data where Processing is no longer justified.
8.4 Right to Restrict Processing: Users may
request limitation of Processing under certain conditions.
8.5 Right to Data Portability: Users may
request to receive their Personal Data in a structured, commonly used format.
8.6 Right to Object: Users may object to
Processing based on legitimate interests or direct marketing.
8.7 Right to Withdraw Consent: Where Processing
is based on consent, Users may withdraw consent at any time.
9. DATA SECURITY MEASURES
9.1 The Controller shall implement appropriate
technical and organizational measures, including encryption, access controls,
and regular security assessments, to protect Personal Data from unauthorized
access, disclosure, alteration, or destruction.
9.2 Third-party Service Providers shall be
contractually bound to maintain equivalent data security standards.
10. DATA SHARING AND INTERNATIONAL TRANSFERS
10.1 The Controller shall not transfer Personal
Data outside Ghana unless:
(a)
Adequate safeguards are in place (e.g., standard contractual clauses).
(b)
The transfer is required by law or permitted by the Act.
10.2 Personal Data may be disclosed to law
enforcement, regulatory authorities, or in response to a valid court order.
11. USE OF AI AND AUTOMATION
11.1 The Service leverages AI models trained on
anonymized data; no automated decision-making producing legal or similarly
significant effects shall occur without human intervention.
11.2 Regular audits and bias assessments shall
be conducted to ensure ethical use of AI.
12. MINORS
12.1 The Service is not directed at individuals
under the age of eighteen (18).
12.2 If Personal Data of a minor is
inadvertently collected, the Controller shall securely delete such data without
undue delay.
13. POLICY GOVERNANCE AND ACCOUNTABILITY
13.1 The Controller shall appoint a Data
Protection Officer (DPO) responsible for overseeing compliance with this Policy
and the Act.
13.2 The Controller shall maintain internal
records of Processing activities and conduct periodic compliance audits.
14. AMENDMENTS TO POLICY
14.1 The Controller reserves the right to
modify this Policy. Material amendments shall be communicated to Users via the
Service and website prior to implementation.
14.2 Continued use of the Service after
notification constitutes acceptance of the updated Policy.
15. CONTACT INFORMATION
For questions or exercise of rights under this
Policy, contact:
Data Protection Officer
Aide Chemists Limited
V194 Broccoli Street
Ashale Botwe, Accra, Ghana
Email: [email protected]
Tel: +233 50 144 8667
