We use your personal information on a lawful basis and for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

a) To operate the Platform and to provide you with access to the associated products and services, we use your personal information to:

• Enter into a contract with you that sets out the terms and conditions of our legal relationship
• provide, operate and improve the Platform and associated services
• provide information about our products and services (subject to opt in and opt out provisions)
• establish and maintain your user profile on the Platform and validate your eligibility or membership status, where applicable
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in
• communicate with you about the Service, including by sending you appointment reminders and support and administrative messages
• provide support and maintenance for the Service
• to respond to your requests, questions and feedback
• provide you with in-app notifications
• process payment information where applicable

 b) To comply with law:

• We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

c) For compliance, fraud prevention, and safety:

• We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

d) With your consent:

• In some cases, we may specifically ask for your consent to collect, use or share your personal information in a manner that you are satisfied with.

e) To create anonymous, aggregated, or de-identified data:

• Subject to any obligations or restrictions we may have under any applicable data processing agreements, we may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect.
• We convert personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you.
• We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Platform and research and development purposes.

 General. Universal does not engage in any automated processing or profiling of Users nor do we sell any personal information.  When services provided by Users are recorded, we do not access the contents of the recordings.

We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

To provide  access to the Platform we need to share your personal information with the following parties, subject to clause 5 (Safeguards) and in addition to the legal justifications contained in the applicable laws, you consent to the sharing of your information with:

a) Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy and subject to applicable laws, regulations and data sharing agreements.

b) Healthcare Providers. If you use the Platform as a patient, we may share your personal information with your selected healthcare provider and/or health establishment.

c) Government or federal departments. Healthcare Reporting. Universal and/or healthcare providers may be required to report statistics and other healthcare information such as a your vaccination status.  We may also share your personal information for the compliance, fraud prevention and safety purposes described above.  Where there is a real threat to a person’s life, health or safety, the relevant authorities must be informed in line with prevailing laws.

d) Healthcare Funders or Insurers. Where applicable, we may share your information with your health funder or Insurer for billing purposes.

e) Employers. If you use the Platform as an employee as part of your employment benefits, only aggravated, de-identified utilization information will be shared with your Employer.

f) Contracted Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy and data sharing agreements, and are prohibited from using or disclosing your information for any other purpose.

g) Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

h) Suppliers and service providers. Information will only be processed to render the services and in terms of a written contract between the supplier or service provider.

a) As a user you have the right to:

• File a privacy complaint if you believe your privacy rights have been violated you can complain to us on the contact details of the Information Officer provided under paragraph 8 below.
• If you remain unhappy with how your information has been processed after raising your concerns with us, you can also lodge a complaint with the relevant local supervisory authority in the applicable jurisdiction
• Request a paper copy of this notice, even if you have agreed to receive it electronically
• Request a restriction on certain uses and disclosures
• Inspect and obtain a copy of your personal information;
• Request a correction or amendment of your personal information
• Access or update your personal information
• Request a list of disclosures made of your personal information within the previous 6 year period
• To update your preferences on how and where we communicate with you.
• Opt-out of marketing communication and/or automate reminders that we or our partners send to you, at any time. Not all of our communications are for marketing, and you’ll continue to receive messages related to your products and services, such as bills, transactional notices, or customer service.
• Appeal a denial of your request by sending a notice to our Privacy Officer via the contact details provided below.

b) As a user you have the following choices when it comes to the processing of your personal information:

• Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the Sites may not work properly.  Similarly, your browser settings may allow you to clear your browser web storage.
• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
• Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information that we process. We have comprehensive information security policies.  We constantly perform risk assessments on our information security to ensure that we have adequate controls in place.

Generally Children are not allowed to use the Platform and their information will not be processed, unless the child is legally authorised by  the relevant laws of the country or state wherein the minor resides to access certain age appropriate healthcare services. Based on the nature of the services accessed on the Platform, a child might have to be assisted by a parent or legal guardian. We encourage parents with queries to contact us at .

a) We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we may notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information).

b) Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes (or as otherwise indicated at the time of posting). In all cases, your continued use of the Platform after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

a) To the extent that information we collect is health data or another special category of personal data subject to relevant data protection legislation, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you pair your device to your account, grant us access to your wellness, exercise or activity data from another service, or use any scanning or measurement features. You can use your account settings and tools to withdraw your consent at any time, including by stopping use of a feature, removing our access to a third-party service, unpairing your device, or deleting your data or your account.

b) Your health information is processed for the following purposes:

• Providing accurate medical or wellness insights.
• Facilitating virtual consultations with healthcare professionals.
• Enhancing the quality of self-assessment tools.
• Maintaining and updating health records securely.
• Offering personalized mental wellness recommendations.

c) Health is only shared with authorized healthcare providers for treatment purposes, when required by law or regulatory authorities or with your consent for participation in research or studies.

Please direct any questions or comments about this Policy or privacy practices to our Information Officer:

a) For South Africa:

Universal House, 15 Tambach Road, Sunninghill Park, Sandton, 2191, South Africa (with email address )

b) For the US:

68 T.W. Alexander Drive, Research Triangle Park, NC 27709 (with email address ).

We retain personal information for as long as required to engage in the practices described in this Privacy Policy unless a longer retention period is required by applicable law or our Retention and Destruction Policy.

a) Universal operates globally, which means personal information may be transferred, stored (for example, in a data center), and processed outside of the country or state where it was initially collected and where some of our users like health care professionals are based.

b) The Universal affiliates have entered into binding corporate rules to govern the sharing of information amongst group companies and includes cross-border processing.

c) Therefore, by accessing the Platform and the services offered by us or disclosing your personal information while using the Platform, you acknowledge and consent to the transfer of your data subject to applicable laws, security safeguards and binding corporate rules. Alternatively you acknowledge that the data transfers are necessary for the performance of the contract that you entered into with us when registering on the Platform. Information is hosted in the UK, the USA and South Africa which all have adequate data protection laws.  Data transfers will only take place under the aforementioned circumstances and if not prohibited by applicable laws.