Privacy Policy

Your privacy and data security are our top priorities. Learn how we collect, use, and protect your personal information.

Effective Date: January 2026

We encourage you to carefully review this document to fully understand the terms, policies, and other important information related to your use of our website, products, and services. This includes details about how we collect, use, and protect your personal information, as well as the ways you can access, modify, or control that information.

Welcome to Penny Medical Tourism Agency (referred to as "Penny," "we," "our," or "us"). These Terms of Service ("Terms") govern your access to and use of our telemedicine platform, website, mobile applications, and associated services (collectively referred to as the "Site" or "Website"). Users of our Site and Services are referred to as "Users," "Members," "you," or "your."

Please note that depending on your region, you may be subject to different privacy and data protection laws, regulations, and standards. We strongly encourage all Users to read this Privacy Policy thoroughly before using our Site or Services. By accessing or using the Site or Services, you agree to the practices described in this Privacy Policy. If you do not agree with any part of this Privacy Policy or related documents, please refrain from using the Site or Services.

Purpose of This Privacy Policy

This Privacy Policy explains how Penny collects, uses, stores, and shares personal information in connection with our Site, mobile applications, and other products or services associated with this policy. When we refer to "personal information," we mean information that can reasonably be used to identify you, either alone or in combination with other data.

Our goal is to be transparent about our privacy practices and to demonstrate our commitment to protecting your personal information. We recognize that you trust us with sensitive information, and we are committed to handling it responsibly and securely.

Information We Collect and How It Is Used

Penny collects various types of information to provide services efficiently, ensure security, and enhance the user experience. The following categories of information may be collected:

a. Personal Information

  • Full name
  • Date of birth and gender
  • Contact details, including email address, phone number, and physical address
  • Identification documents, such as national ID or passport, for verification and travel purposes
  • Preferences related to travel, accommodations, and service requirements

b. Health and Medical Information

  • Medical history, current symptoms, test results, and prescriptions
  • Consultation notes and medical records shared via the platform
  • Diagnostic images, medical reports, and referrals
  • Data provided by healthcare providers with your consent

c. Technical and Usage Information

  • Device type, operating system, and web browser
  • IP address and approximate geographic location
  • Login history and activity logs
  • Cookies and analytics data used to improve Site performance and user experience

d. Payment and Transaction Data

  • Billing and invoicing information
  • Payment transaction records processed through secure third-party gateways

e. Cookies and Tracking Technologies

We use cookies in certain areas of the Website to enhance functionality, remember preferences, and facilitate smoother future visits by reducing the need to repeatedly enter information. Cookies may also be used to personalize content, associate usage with previously submitted information, and recognize returning users. Disabling cookies may limit certain features and reduce overall usability.

Data collected through cookies supports analytics, marketing, promotional efforts, content optimization, and customization of Website layout and services.

How We Use Your Information

Penny is committed to protecting your personal information and will not sell, rent, or otherwise disclose personally identifiable information without your consent, except in the circumstances described below. We may use the information we collect to:

  • Facilitate virtual consultations with licensed healthcare providers and coordinate medical travel, hospital arrangements, and post-treatment care
  • Verify your identity and safeguard your medical records
  • Deliver medical reports, prescriptions, and relevant updates
  • Process payments and provide receipts for services rendered
  • Improve our platform, services, and overall user experience
  • Fulfill legal, ethical, and regulatory obligations, including disclosures required in court proceedings or user-initiated disputes
  • Share personal information with authorized third-party service providers acting on our behalf to deliver services or complete transactions requested by users
  • Communicate with Users via phone, email, messages, or postal mail to provide service updates or important information
  • Use aggregated or anonymized data for analytics, marketing, or promotional purposes, ensuring that individual Users cannot be identified
  • Transfer personal information in the event of a merger, acquisition, or other transfer of business assets, subject to applicable legal requirements
  • Share information as necessary to provide services, collaborate with insurers and related entities, protect user rights, prevent fraud, manage operations, maintain data security, administer health programs, conduct audits or pricing activities, support authorized marketing, and comply with applicable laws and regulations

Security Measures

To protect your personal information, Penny uses industry-standard security measures. When personal data is transmitted to us, it is encrypted using Secure Sockets Layer (SSL) technology or equivalent encryption methods. We also implement organizational and technical safeguards to prevent unauthorized access to the information we collect.

However, it is important to recognize that the Internet and any data transmission method cannot be guaranteed to be completely secure. While we strive to protect your information and adhere to the practices outlined in this Privacy Policy, the Site, its software, hardware, and networks may occasionally experience maintenance, technical issues, or security breaches beyond our control.

User Rights

Unless otherwise specified, providing personal data is mandatory for service delivery. Failure to provide required information may limit or prevent access to certain services.

Users may request further details about the collection or processing of their personal data beyond what is outlined in this Privacy Policy.

How to Amend or Update Your Information

You can review, amend, or update the personal information we collect about you by managing your account profile, contacting us through the provided contact details, or submitting a privacy request. We will respond in accordance with our contractual obligations and applicable legal requirements. In certain cases, we may retain both the original and updated information for purposes such as technical reasons, dispute resolution, troubleshooting, or enforcing agreements.

GDPR Compliance

Where applicable under the GDPR, Users have the right to:

  • Access their personal data
  • Correct or update inaccurate information
  • Request deletion or restriction of processing
  • Object to processing under certain circumstances
  • Receive a portable copy of their personal data

Legal Basis for Processing

Personal Data is processed only when one or more lawful bases apply, including:

  • Consent: Users or their authorized representatives have given explicit permission for specific purposes
  • Contractual Necessity: Processing is required to perform agreements or pre-contractual obligations
  • Legal Obligation: Processing is necessary to comply with applicable laws or regulations
  • Public Interest or Official Authority: Processing supports tasks carried out in the public interest or under official authority
  • Legitimate Interests: Processing is necessary to pursue legitimate interests of Penny or authorized third parties, provided these interests do not override Users' rights

Place of Processing

Personal Data is processed at our offices and data centers in Zambia, as well as in other jurisdictions where our processing partners operate. By using the Website or requesting services, Users consent to the transfer and processing of their Personal Data in Zambia, which may have different data protection standards from other regions.

Data Retention

Personal data is retained only as long as necessary to fulfill the purposes for which it was collected, to comply with contractual obligations, or to satisfy legal or regulatory requirements. In certain circumstances, data may be retained for longer periods if required by law or authorized regulatory authorities.

The provisions of this Privacy Policy remain in effect even after a Member's coverage or account is terminated, for as long as we retain information about that Member.

Children and Minors

Our services are intended for individuals aged 18 years and older. If we learn that personal information has been provided by a minor without parental or guardian consent, we will promptly delete that information. Parents or guardians who become aware that their child under 18 has provided personal information to Penny can contact us to request deletion of such information.

Updates to the Privacy Policy

Penny continually updates and enhances its Site, products and services. We reserve the right to modify or remove sections of this Privacy Policy at any time, at our discretion, and without prior notice unless legally required. Users are encouraged to review this page periodically for updates. Any changes take effect immediately upon posting unless otherwise indicated. Continued use of the Site or Services after modifications are posted constitutes acceptance of the updated Privacy Policy.

Governing Law and Regulatory Compliance

By accessing Penny's Site, using our Services, or sharing information with us, you agree that any disputes relating to privacy or the terms of this Privacy Policy will be governed by the laws of Zambia. You also agree to comply with any liability limitations outlined in our Terms of Service or any other agreements between you and Penny.

Contact Us

For questions, concerns, complaints, or reports of violations relating to these Terms or the Site, you may contact Penny Medical Tourism Agency using the details below:

Penny Medical Tourism Agency

Location:
Zambia (serving international clients)

Data Protection Officer:
HIPAA Privacy Officer

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