Privacy Notice

2.2 Pharmacovigilance purposes

As a player in the human healthcare sector, Life Together has a duty to monitor the safety of the products distributed to patients by collecting and reporting to authorities and manufacturers, where applicable, adverse events that patients may have suffered.

Such monitoring of adverse events is called pharmacovigilance (“PV”). PV requirements exist to allow us, our suppliers, and competent regulatory authorities (such as the Ministry of Health and Wellness in Mauritius and other foreign authorities issuing approvals for product manufacturing) to manage adverse events and to protect public health and ensure the highest standards of quality and the safety of all products marketed locally.

Our PV obligations require us to process personal data of a patient and/or the reporter of an adverse event that we receive in order to comply with our PV reporting obligations towards manufacturers and relevant regulatory authorities.

Pursuant to its PV obligations, we may process your personal data to:

• investigate the adverse event;
• contact the patient or reporter for further information about the adverse event reported;
• collate the information about the adverse event with information about other adverse events that we received to analyse the safety of a production batch, a product or an active ingredient as a whole;
• provide reports to the concerned global wholesalers and manufacturers; and
• provide mandatory reports to competent regulatory authorities (as may be required) so that they can analyse the safety of a production batch, a product and/or generic or active ingredient as a whole.

Furthermore, in compliance with our PV obligations, we may share and/or disclose your personal data:

• with companies involved in the distribution of the product which is subject of the adverse event report;
• with competent regulatory authorities, in respect of a suspected adverse event.

2.3 Marketing purposes

Where you have subscribed for our marketing communications, or our newsletter (by providing Life Together with your telephone number or email address and have indicated to us that you consent to receiving marketing communications via these channels), we may contact you from time to time, whether by SMS, email or otherwise, to inform you about our new developments, services and events that we think may be of interest to you.

You will also be able to opt-out from receiving marketing communications at any time, free of charge, by following the unsubscribe instructions contained in each of our marketing communications or by contacting us in accordance with the section “Contact Us” below.

3. To whom do we disclose personal data?

Your personal data may be shared as follows:

• We will share your personal information with those involved in your health assessment, care, services, or treatment for medical purposes;
• Consulting doctors, external companies or medical practitioners, allied health practitioners may be involved in your health assessment, treatment or care providing you services;
• With our trusted and selected partners, such as imagery and radiology, laboratories, which could be based in Mauritius or abroad;
• In addition to employed medical staff of clinic, there are also a number of visiting doctors and consultants who are not employed by us but who deliver medical services to our patients. These doctors are bound by medical secrecy and deontology;
• Your insurance company for indemnification purposes or claim handling process, where you have consented to it;
• With your employer, in specific circumstances and where you have consented to it;
• between and among other departments of the respective companies listed above as may be relevant for the purposes set out in section 3 above and to facilitate our activities or relationship, but we shall only do so on a strictly need-to-know basis;
• between and among subsidiaries and affiliates of Life Together Ltd as may be relevant for the purposes set out in section 2 above and to facilitate our business activities or relationship, but we shall only do so on a strictly need-to-know basis;
• with our employees for purposes of fulfilling our business activities, treating job applications or conducting internal analysis with a view to improving our company and services;
• with law enforcement bodies/agencies, the Ministry of Health and Wellness, regulatory authorities, and other statutory authorities upon request;
• with our agents, advisers, accountants, auditors, lawyers, other professional advisors, contractors, or third-party service providers for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
• If we were to sell or transfer the clinic, the centres or part of our business to another organisation, your patient and health assessment records would also be transferred to the new owner. Limited information may also be shared, where required, with legal and other professional advisors involved in that transaction. The reason we would transfer your records is to minimise the disruption to current or past patients caused by the sale or transfer and to ensure we and a new owner are able to comply with our legal obligations regarding the retention of patients’ and other clients’ medical records and to ensure continuity of care.

We will ensure that your personal data is kept safely. In addition, third parties with whom we share your personal data will be contractually obliged to confidentiality and to safeguard all personal data to which they have access.

Some disclosures do not require your consent. This happens when we share your personal data with (i) law enforcement bodies/agencies, regulatory authorities, and other statutory authorities, if required by law and (ii) if required or authorized by law or if we suspect any unlawful activities on your part.

Where we have collected your personal data on behalf of another party, the use of your personal data by that party is governed by their privacy policy for which we are not responsible. We may also disclose aggregate or de-identified/anonymized/encrypted data that is not personally identifiable with third parties, including our commercial and strategic partners.

4. Links to other websites

Our website may contain links to other websites, apps, content, services or resources on the internet which are operated by affiliates or third parties. This happens for example when you use the online booking services for an appointment or any services available from time to time on our website. If you access other websites, apps, content, services, or resources using the links provided, please be aware they may have their own privacy policy, and we do not accept any responsibility or liability for these policies or for any personal data which may be collected through these sites. Please check these policies before you submit any personal information to these other websites.

In this context, please note that to facilitate the booking process, the WhatsApp option is available on our website, but the use of WhatsApp is governed by its privacy policy and terms of use which is not under our control. If you do not want to proceed through WhatsApp, we encourage you to call the Nouvelle Clinique du Bon Pasteur Ltée directly for any appointment.

5. Overseas transfers of your personal data

In some cases, we may need to transfer your personal data with organisations located in countries outside our territorial limits in order to provide our services to you. We will take appropriate safeguards in order to secure the personal data being transferred.

Please note that:

• E-mails and e-filing system servers are transferred on Microsoft data cloud based in Ireland.
• Archiving of patient’s records is done in servers based in Europe.
• Some specific medical laboratory analyses are done by our partners based in France or South Africa.

6. How long do we keep your information?

Your personal data will be stored for as long as required to fulfil our business purposes, pharmacovigilance purposes and for the period of time required by law. This is to ensure that information is properly managed and is available whenever and wherever there is a justified need for that information, including to support patient care and continuity of care; to support evidence-based clinical practice and to assist clinical and other audits; to support our legitimate interests, and to meet legal requirements.

To the extent required by law, we will take reasonable steps to destroy or anonymise personal data in a secure manner when we no longer need it for the purposes for which it was collected (as set out in section 3 of this notice) and retention is no longer necessary for legal or business purposes.

Regarding PV data, our obligation is to retain such data (which may include personal data) at least for the duration of the relevant product life cycle and for an additional ten years after the respective pharmaceutical product and medical device has been removed from the market (or for thirty-five years in some cases).

7. Processing of personal data must be justified

We will only process your personal data where we are satisfied that we have an appropriate legal basis to do so, such as (i) for the performance of a contract between us; (ii) where you have provided us with your express consent to process your personal data for a specific purpose; (iii) our use of your personal data is necessary to fulfil our statutory obligations with relevant authorities (regulators, tax officials, law enforcement bodies) or otherwise meet our legal responsibilities; (iv) our use of your personal data is in our legitimate interest as an organisation; (v) for the purpose of preventive or occupational medicine, for the assessment of the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services or pursuant to a contract with a health professional; (vi) for the purpose of carrying out the obligations and exercising specific rights of Life Together or of the patient or any individual; or (vii) protecting the vital interests of our patient or of another person where the patient is physically or legally incapable of giving consent.

Where we process special categories of personal data, we will do so in compliance with the requirements of section 29 of the DPA.

8. Security of personal data

Life Together has in place reasonable technical and organisational measures to prevent unauthorised or accidental access, processing, erasure, loss, or use of your personal data and to keep your personal data confidential. These measures are subject to ongoing review and monitoring.

We cannot guarantee that our website will function without disruptions. We shall not be liable for damages that may result from the use of electronic means of communication, including, but not limited to, damages resulting from the failure or delay in delivery of electronic communications, interception, or manipulation of electronic communications by third parties or by computer programs used for electronic communications and transmission of viruses.

9. Children, minors and next of kin

We may collect and process personal data from minors during the course of our activity and the purpose detailed in section 3, but we will only do so with the permission of your parent or guardian.

In addition, if you are a minor and you are using this website, you may only do so with the permission of your parent or guardian.

10. Access to your personal data

You have the right to request a copy of the personal data we hold about you. To do this, simply contact our Data Protection Officer and specify what data you would like. We will take all reasonable steps to confirm your identity before providing details of your personal data.

You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

11. Correction of your personal data

You have the right to ask us to update, correct or delete your personal data. We will take all reasonable steps to confirm your identity before making changes to personal data we may hold about you. We would appreciate it if you would take the necessary steps to keep your personal data accurate and up to date by notifying us of any changes we need to be aware of.

12. Withdrawal of consent and request for deletion of personal data

You may also withdraw your consent to receiving direct marketing communications, or more generally to our processing of your personal data, at any time, and you may in certain circumstances ask us to delete your personal data. However, we may not be able to fulfil our contractual obligations to you if you entirely withdraw your consent or ask us to delete your personal data entirely. To protect your personal data, we shall require that you first prove your identity to us at the time the request is made, for instance by providing a copy of your national identification card, contact details or answering some other security questions to satisfy ourselves of your identity before we may proceed with your request(s).

Whenever reasonably possible and required, we will strive to grant these rights within 30 days, but our response time will depend on the complexity of your requests. We will generally respond to your requests free of charge unless your request involves processing or retrieving a significant volume of data, or if we consider that your request is unfounded, excessive, or repetitive, in which case we reserve the right to charge a fee (as mentioned above regarding access).

There may be circumstances where we are not able to comply with your requests, typically in relation to a request to erase your personal data or where you object to the processing of your personal data for a specific purpose or where you request that we restrict the use of your personal data where we need to keep your personal data to comply with a legal obligation (including a pharmacovigilance situation) or where we need to use such information to establish, exercise or defend a legal claim. To make these requests, or if you have any questions or complaints about how we handle your personal data or would like us to update the data we maintain about you and your preferences, please contact our Data Protection Officer at the address set out under section 16 below.

13. Cookies policy

Our website uses cookies.

13.1 What is a cookie?

Cookies are small data files that your browser places on your computer or device. Cookies help your browser navigate a website and the cookies themselves cannot collect any data stored on your computer or your files. When a server uses a web browser to read cookies, they can help a website deliver a more user-friendly service. To protect your privacy, your browser only gives a website access to the cookies it has already sent to you.

13.2 Why do we use cookies?

We use cookies to learn more about the way you interact with our content and help us to improve your experience when visiting our website. Cookies remember the type of browser you use and which additional browser software you have installed. They also remember your preferences, such as language and region, which remain as your default settings when you revisit the website. Cookies also allow you to rate pages and fill in comment forms.

The cookies we use are Statistics cookies which help website owners to understand how visitors interact with websites by collecting and reporting information anonymously, and Marketing cookies used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.

13.3 How are third party cookies used?

For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third-party suppliers) may contain third-party cookies and you may wish to consult the policies of these third-party websites for data regarding their use of cookies.

13.4 How do I reject and delete cookies?

We will not use cookies to collect personally identifiable data about you. However, should you wish to do so, you can choose to reject or block the cookies set by the websites of any third-party suppliers by changing your browser settings – see the “Help” function within your browser for further details. Please note that most browsers automatically accept cookies so if you do not wish cookies to be used you may need to actively delete or block the cookies.

You can also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further data on cookies generally. For data on the use of cookies in mobile phone browsers and for details on how to reject or delete such cookies, please refer to your handset manual. Note, however, that if you reject the use of cookies you will still be able to visit our website but some of the functions may not work correctly.

14. Amendments to this Privacy Notice

We may amend this privacy notice from time to time. Any amendment will be posted on our website so that you are always informed of the way we collect and use your personal data. Any changes to this privacy notice will become effective upon posting of the revised privacy notice on the website. Use of our website following such changes constitutes your acceptance of the revised privacy notice then in effect but, to the extent such changes have a material effect on your rights or obligations as regards our handling of your personal data, such changes will only apply to personal data after the changes are applied.

15. Miscellaneous

This privacy notice is governed by and shall be construed in accordance with the laws of the Republic of Mauritius. This privacy notice is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this privacy notice, the English version shall prevail.

16. How to contact us?

We have appointed a Data Protection Officer to oversee compliance with and questions in relation to this notice. If you have any questions about this notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below:

The Data Protection Officer
Life Together Ltd
IBL House Caudan Waterfront
Port Louis
Mauritius
dpo@lifetogether.mu
203 2000

17. Complaints

If you believe we have not handled your request in an appropriate manner, you may lodge a complaint with the Data Protection Commissioner (DPC) (The Data Protection Office, 5th floor, SICOM Tower, Wall Street Ebène, Mauritius). However, we ask that you please try to resolve any issues with us first before referring your complaint to the DPC.

Version dated 1^st of June 2025