Introduction

Aster Sanad Hospital (hereinafter referred to as “The Company”, “we”, “us”, “our”) the “Data Controller” in respect of your Personal Data. The Company provides top-notch hospitals in the Kingdom of Saudi Arabia with specialists and support staff, delivering the best and latest medical care.

We understand the importance of protecting the Personal Data of our Customers (hereinafter referred to as “Customer”, “you”, “user”, “Data Subject”). This Privacy Notice outlines how we process any Personal Data collected from you by accessing, browsing and/or using the website. This Privacy Notice applies only to activities that a customer engages in on this website and does not apply to The Company’s activities that are "offline" or unrelated to the website.

Any capitalized terms used in this Privacy Notice shall have the meanings ascribed to them under applicable Data Protection laws and Regulations.

What Personal Data we collect

• Personal Identifiers: Full name, phone number, email address, age, gender, appointment details (date and time), resume, title, nationality, date of birth, religion, Covid 19 certificate, criminal record, education, work experience, social media job profile (linkedin, indeed),
• Patient Health Data: Health records, health condition
• Account Login and Device Information: IP address, internet domain, browser type, device details, encrypted password etc.
• Customer Satisfaction and survey: Answers to any customer satisfaction surveys, any information received via queries or feedback form.

How and when we collect your Personal Data

The methods by which we collect your Personal Data include but are not limited to the following:

• When you visit our website and engage in activities such as registering or login-in purposes,
• When you make bookings or purchases through the website including doctors’ appointment, home healthcare services, or instant tele-consultations,
• When you apply for a job using our job portal, 
• When you communicate with us through email for the purpose of recruitment and /or recruitment related queries,
• When you communicate with us through social networking websites, third-party applications, or similar technologies.

Information from Third-Party Services

If you access the services from an advertisement on a third-party website, application, or other service (a “Third-Party Service”) we may receive information from the owner of the Third-Party Service related to you or that advertisement.

Use of Your Personal Data

Your Personal Data may be used or processed for various purposes including but not limited to the following:

• (www.astersanad.sa) collects certain anonymous data regarding the usage of the website. This information does not personally identify users, by itself or in combination with other information, and is gathered to improve the performance of the website.
• To maintain internal records,
• To allow new users to register on our website and/or allow both new as well as existing users to book appointments,
• To advertise the products and services of Aster Sanad and send you updates about new products, special offers, and other information that may interest you at the email address you provided, 
• To send promotional communications via SMS, WhatsApp, email, and other channels, and to support related services such as customer support, marketing, analytics, advertising, and performance tracking etc.
• To carry out insurance-related purposes, including claims processing, verification, and billing.
• To perform studies, research, and analysis for improving our information, services, and technologies and ensure that the content displayed is customized to your interests and preferences based on your feedback,
• To administer or otherwise carry out our obligations in relation to any agreement you have with us,
• To comply with legal and regulatory requirements, including responding to court orders, or legal processes, establishing or exercising our legal rights, defending against legal claims, and investigating, preventing, or taking action regarding illegal activities, suspected fraud, violations of our terms of use, breaches of our agreement with you, or as otherwise required by law.

If you are a job applicant, your Personal Data will be collected and used by us for the following purposes, and we may disclose your Personal Data to third parties where necessary for the following purposes:

• Assessing and evaluating your suitability for employment in any current or prospective position within the organization; and
• Verifying your identity and the accuracy of your personal details and other information provided.

Legal Basis for Processing of Your Personal Data

We will only process your Personal Data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your Personal Data. In almost every case, the legal basis will be one of the following:

1. Consent: For example, where you have provided your consent to receive certain marketing/promotional messages from us or where you have provided your explicit consent for us to process your data during live telemedicine consultation services under tele-medcare. 
2. Our legitimate interest: Where it is necessary for us to understand our customers, promote our services, and effectively provide services, provided in each case that this is done in a legitimate way that does not duly affect your privacy and other rights. 
3. Compliance with law/agreement: Where we are subject to a legal obligation and need to use your Personal Data in order to comply with that obligation. For example, when you may purchase products/services from us, or book appointments we need to use your contact details and payment information in order to process your order. 
4. Vital Interests: In some limited cases, we may need to process your Personal Data where it is necessary to protect your vital interests or the vital interests of another person. 

We will always take steps to ensure that the processing of your Personal Data is fair and lawful and that it does not unduly affect your privacy.

AI Usage

We may use Artificial Intelligence (AI) technologies to enhance healthcare services, including but not limited to supporting diagnostic processes, personalizing treatment recommendations, and automating certain administrative and clinical workflows. These tools are used in accordance with applicable legal and regulatory guidelines, and are subject to internal assessments to ensure accuracy, fairness, and patient safety.

Wherever applicable, separate and explicit consent will be obtained from individuals prior to the use of AI tools in processing their health data or delivering AI-assisted healthcare services.

Children’s Privacy

We understand the importance of taking extra precautions to protect the Privacy and safety of children using our website or services. Minors are not permitted to use the website or services, and we request that minors under the age of 18 do not submit any Personal Data to the website. Since information regarding minors under the age of 18 is not collected, we do not knowingly distribute Personal Data regarding Minors under the age of 18. By accessing this website, you affirm and guarantee that you are 18 years of age or older. We hold no liability for any unsolicited information provided by you, and you consent to the usage of such information in accordance with this Privacy Notice. If we become aware that a person submitting personal data is under 18, we will delete all the information as soon as possible unless it is with the consent and involvement of a parent or guardian. If you believe we might have any information from or about a child under 18, please contact us via email at Privacy@asterdmhealthcare.com.

Term of storage of Personal Data

We take diligent measures to ensure that the Personal Data you provide us is retained only for as long as necessary for the purpose for which it was collected, and for satisfying any legal, accounting or reporting requirements or as required by any applicable law. 

If you withdraw your consent from marketing, we will remove your credentials from the marketing database.

Sharing and Transferring of Personal Data

Basis your consent, you authorize us to exchange, transfer, share, your Personal Data within the Aster Sanad affiliates/agents/third party service providers/partners/authorities, Health Information Systems (HIS) and from your country to any other countries across the world for legal documentation, insurance processing, marketing purposes, or for providing our services for the purposes specified under this Notice or as may be required by applicable laws and regulations. 

We may share your information with authorized third-party vendors and service providers that help us with specialized services, including customer service, email deployment, business analytics, marketing (including but not limited to advertising, attribution, deep-linking, direct mail, mobile marketing, optimization and retargeting) advertising, performance monitoring, hosting, and data processing. These authorized third-party vendors are subject to risk assessment test and will not use your information for purposes other than those related to the services they are providing to us. All such data sharing is conducted in accordance with applicable data localization requirements, security protocols, and applicable regulatory standards.

If you choose to engage in public activities on the third-party sites that we link to, you should be aware that any information you share there can be read, collected, or used by other users of these sites and forums. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in public areas.

Please note that, in line with regulatory requirements and basis your consent, all health-related data is securely shared with government-mandated Health Information Exchanges (HIEs) and other applicable platforms to support better care coordination and public health outcomes. 

You acknowledge that some countries where we may transfer your Personal Data may not have adequate data protection regime or laws that are as stringent as the laws of your own country. You acknowledge that it is adequate that when Aster Sanad transfers your Personal Data to any other entity within or outside your country of residence, Aster Sanad will place contractual obligations along with technical and organizational measures on the transferee which will oblige the transferee to adhere to the provisions of this Notice. Additionally, the principle of data localization is followed, where applicable, in accordance with KSA PDPL, 2023. Thus, Personal Data is stored within the same jurisdiction as its collection to ensure the accuracy and integrity of the Personal Data. 

Exceptions

There are certain exceptions under which Patient Health Information can be transferred or shared outside the country of collection, by virtue of a decision issued by the Federal or local governmental Health authority in the State and after getting approval from the Saudi Data & AI Authority wherever applicable. Such exceptions include, but are not limited to:

• Cases of extreme necessity to preserve the life of the data owner 
• Vital interests of data owner 
• Examine or treat an infection 
• Serve the interests of the Kingdom 
• Implementation of an obligation under a convention to which the Kingdom is a party

Disclaimer

We define Patient Health Information as information that includes or pertains to:

1. Your personal health, which may consist of your medical history. 
2. Your physical traits, such as weight and height.
3. Any disabilities you have or have had.
4. Any healthcare services provided or being provided to you.
5. Information provided by you related to the donation of your body part or bodily substance or obtained from the examination or testing of your body part or bodily substance.
6. Information collected before or during the provision of healthcare services incidental to your care.
7. Any other information or documents you choose to disclose.

Your Rights and Control over your Personal Data

We will respect your legal rights in relation to your Personal Data. Aster Sanad is committed to protecting them and ensuring compliance if you wish to exercise any of the rights under the Kingdom of Saudi Arabia’ Personal Data Protection Law, 2023.

1. For Users in the Kingdom of Saudi Arabia

1. Right to be informed – Aster Sanad can provide clear and concise information about what is done with your Personal Data and its purpose.
2. Right to rectification – You have the right to request correction of your Personal Data if the information is incorrect, including the right to have incomplete Personal Data completed.
3. Right to erasure – You have the right to request to rectify, block or erase your Personal Data when the processing of such data is inaccurate, incomplete, or outdated
4. Right to access personal Data – You have a Right to Access your Personal Data available with Aster Sanad, which includes accessing it and obtaining a copy of it in a clear and readable format.
5. Right of correction – You have the right to request correction of your Personal Data if the information is incorrect, including the right to have incomplete Personal Data completed.
6. Right of erasure/ destruction of data – You have the right to get your Personal Data erased or removed at any time except: 

• If your request affects the investigation procedures, claims for rights and Legal proceedings or defence by Aster Sanad Hospital. 
• Your request conflicts with other legislation to which Aster Sanad Hospitals is subject. 

1. Right to withdraw consent - You have a right to withdraw consent at any time from further processing your data.

To exercise any of your above-mentioned rights, please contact us at privacy@asterdmhealtcare.com.  

We will respond to your access request as soon as reasonably possible and/or as per the applicable timeframes laid down by the respective Privacy laws/regulations. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing of the same as soon as practically possible. If we are unable to provide you with your Personal Data or to make a correction requested by you, we shall inform you of the reasons why we are unable to do so (except where we are not required to do so under the law).

Please note that depending on the request that is being made, we will only need to provide you with access to the Personal Data contained in the documents requested, and not to the entire documents themselves. For example, The Company may not be obliged to provide the employee with access to the disciplinary records, investigation reports, or decisions to terminate, that the organization has created for evaluative and/or investigative purposes of the employee.

The Company is committed to protect your privacy. To respect your preferences, we provide multiple ways to opt out of receiving marketing and promotional communications. You can do this at any time using the unsubscribe or opt-out links provided in our emails and messages. If you wish to withdraw your consent for marketing or for the sharing of information, you can do so by writing to us through an email at privacy@asterdmhealtcare.com requesting the same. Once you withdraw your consent to share the Personal Data collected by us, we shall have the option not to fulfil the purposes for which the said Personal Data was sought, and we may restrict you from using our services or the website or parts of it as the case may be.

Security

The security of your Personal Data is important to us. We have adopted and maintained reasonable technical and organizational security measures and procedures including access governance and information sharing on a need-to-know basis, password protection, encryption etc. to ensure that the Personal Data collected is secure. We restrict access to your Personal Data to our and our affiliates’ employees, agents, third-party service providers, partners, and agencies on a need-to-know basis and are absolutely limited to the purposes as specified above in this Notice.

Use of Cookies

• Cookies are small bits of data cached in a user’s browser. Aster Sanad utilises cookies to determine whether or not you have visited the home page in the past. However, no other user information is gathered. We may use non-personal "aggregated data" to enhance the operation of our website or analyse interest in the areas of our website. 
• If you would like to find out more about cookies, including how we use them and what choices are available to you, please refer to our Cookie Policy.
• You may also be able to control or limit the collection of this technical data through your browser or device settings.

 International Users and Personal Data

We welcome users from around the world and are committed to respecting their privacy. We encourage them to visit Aster Medical Travel on (https://astermedicaltravel.ae) for more details on how we handle their Personal Data.

Modifications to this Privacy Notice

The website Privacy Notice and terms & conditions would be changed or updated occasionally to meet the requirements and standards. Therefore, customers are encouraged to frequently visit these sections in order to be updated about the changes on the website. Modifications will be effective on the day they are posted and the date of this Privacy Notice of when it was last updated will appear at the top of this document.

Contact Us

If you have any questions regarding this Privacy Notice, you may contact our Group Data Protection Officer:

DPO Details: privacy@asterdmhealtcare.com 

Contact No.- +971565037221

Or you can write to us/post at:

The Data Protection Officer,

Aster DM Healthcare Limited.

Official Address: 33rd Floor - Aspect Tower, Business Bay, P.O. Box: 8703 - Dubai - U.A.E

If you have any questions, concerns, or complaints regarding our compliance with the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by data protection laws.