EfyCare Privacy Policy

1. Introduction

1.1 Welcome to EfyCare ("Mental Wellness Platform", "we", "our", or "us").

1.2 This Privacy Policy explains how we collect, use, process, store, disclose, transfer, and protect personal information obtained through our online platform that facilitates connections between patients seeking psychological and mental health services and licensed psychologists, counsellors, therapists, psychiatrists, and other qualified mental health professionals ("Psychologists").

1.3 We recognize that information relating to an individual's mental health is highly confidential and sensitive. We are committed to safeguarding the privacy, dignity, and confidentiality of all users in accordance with applicable laws, including but not limited to:

• The Constitution of Kenya, 2010;
• The Data Protection Act, 2019 (Kenya);
• The Data Protection (General) Regulations, 2021;
• The Data Protection (Registration of Data Controllers and Data Processors) Regulations, 2021;
• The Health Act, 2017;
• Applicable professional ethical standards governing psychologists;
• Any other applicable local and international privacy and data protection legislation.

1.4 By creating an account, accessing, or using the Platform, you acknowledge that you have read, understood, and agree to this Privacy Policy.

2. Definitions

2.1 Unless the context otherwise requires:

• Account means a registered user profile on the Platform.
• Patient means any individual seeking mental health services through the Platform.
• Psychologist means a duly qualified, licensed, registered or accredited mental health practitioner using the Platform to provide professional services.
• Personal Data means any information relating to an identified or identifiable natural person.
• Processing includes collecting, recording, organizing, storing, consulting, using, sharing, transmitting, deleting, or otherwise handling personal data.
• Sensitive Personal Data includes information concerning: Physical health; Mental health; Psychological assessments; Medical history; Therapy records; Sexual orientation where disclosed; Biometric information; Identification documents; Religious beliefs where relevant to treatment; Any information classified as sensitive under applicable law.

3. Scope of this policy

3.1 This Privacy Policy applies to: Patients; Psychologists; Visitors; Corporate clients; Institutions; Mobile application users; Website users; Any third party accessing the Platform.

4. Our role

4.1 Depending on the circumstances under applicable data protection legislation, we may act as: A Data Controller; A Joint Data Controller; A Data Processor.

4.2 Psychologists remain independently responsible for maintaining the confidentiality of clinical records under applicable professional laws.

5. Information we collect

We may collect the following information:

• Personal Information: Full names, Date of birth, Nationality, Gender, National ID, Passport number, Telephone number, Email address, Postal address, County and country, Emergency contact details.
• Account Information: Username, Password (encrypted), Security questions, Login history, User preferences, Language preferences.
• Health Information: Mental health history, Psychological assessments, Diagnosis, Medical conditions, Therapy goals, Treatment plans, Medication history, Progress notes, Clinical observations, Referrals, Previous counselling history, Crisis intervention notes.
• Appointment Information: Bookings, Consultation dates, Attendance records, Session duration, Missed appointments, Cancellation history.
• Payment Information: Mobile money transactions, Credit card tokens, Bank details, Billing information, Receipts (The Platform does not store complete debit or credit card details).
• Device Information: Device ID, Browser type, IP address, Cookies, Operating system, Time zone, Session duration, Crash logs, Analytics.
• Communications: Messages exchanged through the Platform, Emails, Support tickets, Feedback, Surveys, Complaints.

6. Consent

30.1 By creating an account, accessing the Platform, booking appointments, or using any services available through the Platform, you expressly acknowledge and agree that: you have read and understood this Privacy Policy; you consent to the collection and processing of your personal and sensitive personal data for the purposes described herein; where you are a Psychologist, you acknowledge your independent legal and ethical obligations to safeguard patient confidentiality; you understand that consent may be withdrawn at any time, subject to legal limitations.