​1. Introduction

1.1 PHONEDOC (Pty) LTD (Registration Number 2021/303716/0) is a proudly South

African Company established to provide patients with access to General Practitioners

and Specialists at all times at an affordable cost. Patients will be given professional

advice and telephonic assessments by doctors who will decide if the patients require

an immediate hospital visit or not.

1.2 PHONEDOC respects your right as a data subject to privacy and is committed to

the protection thereof. This Privacy Policy explains how we process the Personal

Information we collect from you and also informs you of your rights in terms of the

Protection of Personal Information Act, Act 4 of 2013 (“POPIA”). Accordingly, this

Privacy Policy explains, amongst other things:

1.2.1 What Personal Information PHONEDOC collects;

1.2.2 For what purpose PHONEDOC collects Personal Information;

1.2.3 How PHONEDOC collects Personal Information;

1.2.4 How long PHONEDOC retains Personal Information; and

1.2.5 Your rights as a data subject.

1.3 By the usage of our services, website and App, supplying services to PHONEDOC

and submitting any information to PHONEDOC, you acknowledge and agree that

such conduct constitutes unconditional, specific and voluntary consent to the

processing of your Personal Information in accordance with this Privacy Policy,

whether or not by automatic means.

1.4 This Privacy Policy should be read in conjunction with the POPIA and its Regulations,

where applicable.

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2. Principles

2.1 PHONEDOC has implemented the following approach concerning Personal

Information:

2.1.1 To be transparent in its standard operating procedures that govern the

collection and processing of Personal Information;

2.1.2 To comply with all applicable legal and regulatory requirements regarding the

processing of Personal Information;

2.1.3 To collect Personal Information by lawful and transparent means and to

process Personal Information in a manner compatible with the purpose for

which they were collected;

2.1.4 To strive to keep personal Information accurate, complete and up-to-date and

reliable for their intended use;

2.1.5 To develop reliable, safe and sustainable means of protecting the Personal

Information of individuals whether physical or digitally so as to prevent

leakage, loss, alteration or misuse of said information;

2.1.6 When consigning to outside entities for the protection of said information,

PHONEDOC will only select those with the ability to safeguard and manage

the said information.

2.1.7 This policy will be made known to PHONEDOC's service providers, suppliers,

patients, employees or prospective employees, and

2.1.8 PHONEDOC will strive to continuously improve this policy and all other

systems for the protection of Personal Information so as to adapt to a

changing environment or according to legal needs.

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3. Personal Information collected by PHONEDOC

3.1 Personal information is defined by POPIA as information relating to an identifiable,

living, natural person, and where it is applicable, an identifiable, existing juristic

person, including, but not limited to:

3.1.1 Information relating to the race, gender, sex, pregnancy, marital status, national,

ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-

being, disability, religion, conscience, belief, culture, language and birth of the person;

3.1.2 Information relating to the education or the medical, financial, criminal or employment

history of a person;

3.1.3 Any identifying number, symbol, e-mail address, physical address, telephone number,

location information, online identifier or other particular assignment to the person;

3.1.4 The fingerprints or other biometric information of the person;

3.1.5 The personal opinions, views or preferences of the person;

3.1.6 Correspondence sent by the person that is implicitly or explicitly of a private or

confidential nature or further correspondence that would reveal the content of the

original correspondence;

3.1.7 The view or opinions of another individual about the person; and

3.1.8 The name of the person if it appears with other Personal Information relating to the

person or if the disclosure of the name itself would reveal information about the

person.

3.2 We may process any of the types of Personal Information as defined above, although

it will only be processed in so far as it is adequate, necessary, relevant and not

excessive in relation to the purposes for which it is required.

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4. Purpose for which Personal Information is collected by PHONEDOC

4.1 Primarily, we use your Personal Information to conduct a telephony medical

consultation service between our Service Providers who are medical doctors and

members of the public who require such service.

4.2 The purpose for which we use your Personal Information is ultimately dependent on

our relationship with you and will include amongst others:

4.2.1 When you are a patient:

4.2.1.1 identify you;

4.2.1.2 obtain your medical ailment or medical history;

4.2.1.3 administer and manage the services we offer to you; and

4.2.1.4 obtain your credit or debit banking card details for the purposes of payment

for the services we render to you;

4.2.2 When you are a supplier or service provider:

4.2.2.1 identify the individual or company and conduct appropriate checks, audits,

due diligence and procedures;

4.2.2.2 payment for the goods and/or services acquired and used;

4.2.2.3 communication in relation to the goods and/or services supplied;

4.2.2.4 review, compare and evaluate the goods and/or services supplied;

4.2.2.5 record keeping in accordance with the applicable legislation;

4.2.2.6 performance of the parties’ respective obligations under the applicable

agreement for the supply of the goods and/or services.

4.2.3 When you are an employee or prospective employee:

4.2.3.1 identify you and conduct appropriate checks, audits and procedures;

4.2.3.2 payment of employment benefits and related deductions;

4.2.3.3 record keeping and reporting in accordance with the applicable legislation;

4.2.3.4 contacting purposes;

4.2.3.5 provision of access to PHONEDOC'S premises and/or access to its resources;

4.2.3.6 review and evaluate your work experience and qualifications; and

4.2.3.7 recruitment purposes.

4.3 Further, we may use your Personal Information to:

4.3.1 pursue our legitimate interests such as to compile reports and statistical

analysis;

4.3.2 comply with requests for information from any internal or external auditor, or

any regulatory body;

4.3.3 provide you with information about our products and services from time to

time via email, telephone or other means;

4.3.4 meet legal and regulatory requirements to which we may be subject;

4.3.5 use in connection with legal proceedings; and

4.3.6 assist with any criminal or similar investigation.

4.4 PHONEDOC may share your Personal Information with the following third parties:

4.4.1 Those required in order to meet our transactional or contractual obligations to

you (such as suppliers, service providers or patients, as the case might be);

4.4.2 PHONEDOC'S external auditors; and

4.4.3 Regulators, governments and law enforcement authorities.

4.5 Where PHONEDOC shares your Personal Information with the above third parties, the

latter will be obliged to use that personal information for the reasons and purposes it

was disclosed for. To this end, we have agreements in place with these third parties

to ensure this.

4.6 Your Personal Information may also for cloud storage purposes or through the use of

our website or app, be transferred or processed outside of the Republic of South

Africa. Any disclosures of your Personal Information to third parties outside South

Africa are done in line with the requirements set out in section 72 of POPIA.

4.7 Unless you have consented, PHONEDOC will not sell, exchange, transfer or otherwise

make available any personal information about you to any other parties and you

indemnify PHONEDOC from any unintentional disclosure of such information to

unauthorised persons.

4.8 You may refuse to provide us with your Personal Information in which case it is likely

that we will not be able to meet our obligations to you or would have to terminate our

relationship.

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5. How PHONEDOC collects Personal Information

5.1 PHONEDOC collects Personal Information in the following manner:

5.1.1 If you're a patient, then directly from you: We collect most Personal

Information directly from you, for example capturing of details when making

use of our telephony medical consultation service.

5.1.2 If you're a patient, from our Service Providers: These are the doctors who

consult with you over the telephone.

5.1.3 If you're a service provider or supplier, then from the information that you

provide to us.

5.2 From third parties: Occasionally we will collect or process Personal Information

obtained from third party sources or sources in the public domain, such as the Health

Professions Council of South Africa. We will inform you prior to conducting any credit

and fraud checks.

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6. Retention Period of Personal Information

6.1 In accordance with POPIA, PHONEDOC will keep your Personal Information on record

for as long as:

6.1.1 It is legally obliged to do so;

6.1.2 A contract or agreement with you requires us to keep it;

6.1.3 You have consented to us keeping it;

6.1.4 We reasonably require it to achieve the purpose set out in the terms of

transaction or contract with you;

6.1.5 We require it for legitimate business purposes; or

6.1.6 There is ongoing litigation, investigation or tax or other regulatory query

relating to the Personal Information.

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7. Your Rights as a Data Subject

7.1 As a data subject you have a legal right in terms of POPIA to:

7.1.1 Request access to your Personal Information we hold;

7.1.2 Request correct and/or deletion of your Personal Information we hold;

7.1.3 Request the restriction of or object to the processing of your Personal

Information we hold;

7.1.4 Withdraw your consent to the processing of your Personal Information;

7.1.5 Withdraw your consent to receiving marketing messages from us; and

7.1.6 Complain to the Information Regulator as set out below.

7..2 For further information on how to exercise these rights, please refer to the POPI Act

or resources available on our website at https://www.phonedoc.co.za/.

7.3 Important to note with regards to your rights is the following:

7.3.1 We will require adequate proof of identification from you prior to responding

to you (which we will do within a reasonable time);

7.3.2 We will correct or delete information unless we are required or entitled to keep

such information under applicable laws, in which case we will inform you.

7..3.3 If we believe information does not require correction, we will provide you with

credible reasoning for such.

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8. Cookies

Our website makes use of “cookies” to automatically collect information and data through the

standard operation of the Internet servers. “Cookies” are small text files a website can use

(and which we may use) to recognise repeat users, facilitate the user’s on-going access to

and use of a website and allow a website to track usage behaviour and compile aggregate

data that will allow the website operator to improve the functionality of the website and its

content, and to display more focused advertising to a user by way of third party tools. The

type of information collected by cookies is not used to personally identify you. If you do not

want information collected through the use of cookies, there is a simple procedure in most

browsers that allows you to deny or accept the cookie feature. Please note that cookies may

be necessary to provide you with certain features available on our website, and thus if you

disable the cookies on your browser you may not be able to use those features, and your

access to our Websites will therefore be limited.

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9. Security Breaches

9.1 PHONEDOC has implemented appropriate technical and structural security measures

to protect Personal Information that is in its possession against accidental or illegal

damage, loss, modification, unauthorised disclosure, or unauthorised access, in

accordance with applicable laws. Despite these measures, you acknowledge that

Personal Information may be accessed by an unauthorised third party (for e.g. as a

result of criminal activity).

9.2 In the event of a data breach leading to the accidental or illegal damage, loss,

modification, unauthorised disclosure or any unauthorised access to any Personal

Information that has been transmitted, stored or otherwise processed by PHONEDOC,

the company has the relevant instruments and policies in place in order to cater for

and assess the details relating to any such data breach in a prompt and efficient

manner. PHONEDOC will notify you of such data breach as soon as possible in

accordance with POPIA.

9.3 As stated above, when we contract with third parties, we conclude agreements with

them in terms of which we impose appropriate security, privacy and confidentiality

obligations on them to ensure that personal information is kept secure.

9.4 Whilst we will do all things reasonably necessary to protect your rights of privacy, we

cannot guarantee or accept any liability whatsoever for unauthorised or unlawful

disclosures of your personal information, whilst in our possession, made by third

parties who are not subject to our control, unless such disclosure is as a result of our

gross negligence.

9.5 If you disclose your personal information to a third party, such as an entity that

operates a website linked to our website or anyone other than the PHONEDOC, we

shall not be liable for any loss or damage, howsoever arising, suffered by you as a

result of the disclosure of such information to the third party. This is because we do

not regulate or control how that third party uses your personal information. You

should always ensure that you read the privacy policy of any third party.

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10. The Information Regulator

10.1 Should you wish to lodge a complaint with the Information Regulator related to this

Privacy Policy, you may do so in the prescribed manner and form.

10.2 The address of the Information Regulator is as follows:

The Information Regulator (South Africa)

33 Hoofd Street

Forum III, 3rd Floor Braampark

PO Box 31533

Braamfontein, Johannesburg, 2017

Complaints email: complaints.IR@justice.gov.za

General enquiries email: inforeg@justice.gov.za

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11. Updates to the Privacy Policy

11.1 This Privacy Policy has been reviewed and approved by PHONEDOC's

Information Officer, and is subject to change without prior notice. The most

current policy will be available at any time on our websites. This Privacy Policy is dated

03 August 2025

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12. Contact Us

12.1 Should you have any questions, concerns or requests related to this Privacy Policy,

please contact PHONEDOC's Information Officer at info@phonedoc.co.za.