Last updated: 2022.04.11
Clobo Inc. (hereinafter the " Clobo”) operates an online healthcare consultation platform (“Dr. CLOBOlobo”) through both a dedicated application and an internet website. Please read the following carefully before using this website.
We, Clobo, respect your privacy. As we operate our website and application, and provide you with our services, we process personal data about you in accordance with applicable data protection laws, including the General Data Protection Regulation of the European Union (the "GDPR"), the Children's Online Privacy Protection Act (the “COPPA”) of the USA, the Delaware Online Privacy and Protection Act (the "DOPPA"), and the Student Data Privacy Protection Act (the “SDPPA”), etc.
1. RESPONSIBLE CONTROLLER
2. HOW WE PROCESS YOUR PERSONAL DATA
As we provide you with our services on our website and application, we collect, use, store, generate or disclose to third-parties (hereinafter collectively referred to as "process") your personal data with a legal basis such as your consent and the applicable laws and regulations, etc. for the following purposes:
1) To manage the membership service of the Dr.CLOBO for the purpose of providing the service to our members, i.e. confirmation of intention to join the membership, identification of members or users, and confirmation of intention to withdraw from or terminate the membership;
2) To secure a communication channel with our members and/or users, for the purpose of the payment of service fees, dealing with consultation and inquiries, delivery of notices and handling complaints;
3) To use the member's card information to the extent necessary for the payment procedure or cancellation of payment where the member registers his or her credit card to pay for our service;
4) To develop and improve our services, such as providing customized service or advertisement based on the personal information and content of the consultation, which is more likely to be of our member’s interest;
5) To provide customized service or advertisement through analysis of the records of use of service, the frequency of access to service and statistics on use of service;
6) For medical members, to confirm relevant experience and qualifications necessary to provide consultation service;
7) To protect users or our members’ interests and ensure the operation of service by restricting the use by the members who violate relevant laws and regulations or the Terms of service of Dr.CLOBO, by preventing and sanctioning acts, including illegal use of service, that impedes the smooth operation of the service, by preventing account or identity theft and illegal transactions thereof, by preserving records for dispute resolution, and by handling complaints arising from or in respect of the use of service;
8) In respect of the events held for marketing and promotion purposes, to provide information regarding events, opportunities of participation in such events, and information on advertisments in respect of the events to participants, etc.; and
9) To establish an environment of use of service for the users and our members to use with confidence in other aspects of security, privacy, and safety, etc.
3. PERSONAL DATA TO BE COLLECTED
1) For the Members:
a) Information required for membership registration: email address, ID, password, telephone number;
b) Information required for purchase and payment: credit card company, card number, expiration date, CVC, the first two digits of the password. date of birth (or business registration number);
c) Sensitive personal information necessary for healthcare consultations with the Medical members (see Article 4 below for further information);
d) Other information required for providing the service such as records of use of service and information about devices (i.e. informaton about App and OS version, etc.).
2) For the Medical members:
a) Information required for membership registration: email address, ID, password, telephone number;
b) Information required for verifying qualifications in respect of providing consultation services: the doctor (and/or dentist) license number and the image of the license, the license issuing agency, educational background, work experience, certificate of qualifications, area of residence, etc;
c) Information required for payment and settlement of consultation fees: bank information, account number, copy of ID, etc;
d) We may periodically check or verify the validity of the information that may change, such as the Medical member's academic background, career, and qualifications, and that would be necessary for the operation of service, among the information provided by the Medical member.
4. SENSITIVE PERSONAL DATA: HEALTH DATA
1) In order to provide online healthcare consultation to Members, personal health data such as medical records and diagnosis may be collected in light of the nature of the consultation service, which is sensitive information under the applicable Privacy Protection Acts.
2) Except for the health data as stipulated in above paragraph 1) of this Article, we usually do not collect and/or use sensitive categories of your personal data as defined in Articles 9 or 10 of GDPR on our website and application.
3) In particular, in relation to the health data, we strictly comply with the applicable laws and regulations, and collect and process information only within the scope necessary to provide our services. The health data is collected only when an informed consent (i.e. informed consent means that individual signs a consent form that includes a description of the information to be collected and/or retained and its purpose and potential uses) is obtained from the data subject, and, except as required by law, all collected information shall not be provided or disclosed to a third party other than Medical members of the Dr.CLOBO. The Medical member shall pay special attention to sensitive personal information that he or she acquires or gets to know in the course of consultation services they provide and shall not disclose these Member's personal information and sensitive personal information without prior consent.
4) Members may not provide health data if he or she does not want to provide it, in which cases, the use of service may be restricted.
5. PROVISION OF PERSONAL DATA TO THIRD PARTY
1) We do not provide personal information to any third parties without the prior consent of users or our members; provided. however, that the personal information may be provided only when the users or the members directly consent to the provision of personal information in order to use the services provided by an external partner, or when the relevant laws and regulations require us to submit personal information.
2) Even when providing personal information to a third party, it can be provided after notifying the user or member of the relevant fact including a description of the information to be collected and/or retained and its purpose and potential uses, and obtaining consent thereto, in accordance with applicable laws and regulations; provided, however, that such consent may be omitted in exceptional cases where permitted by lawd and requlations. For example, law enforcement is permitted to forgo the informed consent requirement if needed to establish an individual's identity during the course of a criminal investigation, to determine paternity, or to determine the identity of a deceased individual.
3) Recipients we disclose your personal data to:
a) Our contractors that help us receive, handle and respond to your inquiries;
b) Our contractors that assist us in providing the website, and our group companies and/or third parties we use to help us provide you with our services;
c) Our advertising partners;
d) Our contractors that assist us in analyzing web traffic data for the purpose of improving our services and marketing;
e) Our contractors that assist us in monitoring web access traffic for the purpose of security of our website and appliclation.
6. STORAGE AND DESTRUCTION OF PERSONAL DATA
We, in principle, retain your personal data for as long as you register on our website and/or application, or until you withdraw your consent. In that regard, if you withdraw from your membership of Dr.CLOBO, the personal information collected shall be destroyed without delay; provided, however, that if we have obtained separate consent for the retention period of personal information, or if the relevant laws and regulations impose an obligation to keep information for a certain period of time, the personal information will be safely stored for that period.
A cookie is a small text file that our browser send to your device for the purpose of keeping certain records.
By using cookies:
(1) Your devices remember your preferences (e.g. language used) and activities (e.g. login status, items in cart, etc.) on our browser so that we can deliver a personalized and better user experience on our browser (essential cookies);
(2) We keep track of your interactions with our browser, giving us useful and important insight for improving our browser (performance cookies); and
(3) Based on your consent, our advertising partners keep track of your browsing history across the Internet, so that we can deliver personalized advertisement that is more likely to be of your interest (advertising cookies).
For more information and to change your cookie settings, including withdrawal of your consent, visit our "COOKIES" section at app setting.
8. TRANSFER TO OTHER COUNTRIES
We do not transfer your personal data to any entities located in any third countries outside of the USA, Korea or Japan. In the event that we transfer your data to an entity located outside these countries, we protect your rights with personal data by virtue of a data transfer contract with the relevant recipient in accordance with the applicable laws and regulations such as the GDPR, which imposes on such recipients contractual obligations to ensure an adequate level of data protection equivalent to those laid down by the GDPR.
9. YOUR LEGAL RIGHTS
Provided that certain conditions are met, you have legal rights to request from us the following:
a) Revocation of the previously given consent to our processing of your personal data
b) Access to your personal data and to certain supplementary information covered by this policy;
c) Rectification of your personal data if inaccurate or incomplete;
d) Erasure of your personal data in certain circumstances;
e) Suspension of using your personal data in certain circumstances;
f) Stopping processing your personal data in certain circumstances; and
g) Obtaining your personal data in a structured, commonly used, and machine-readable format.
If you wish to exercise your rights, please contact us.
10. HOW DOES OUR SITE RESPOND TO "DO NOT TRACK" SIGNALS
Some web browsers incorporate a "Do Not Track" (DNT) feature that sends signals to websites and/or application you visit that you do not want to be tracked when turned on. Our site responds to the DNT signals. You can confirm your settings by going directly to our Cookie Settings page. You can also click on the "Do Not Sell My Personal Information" link at the bottom of every webpage.
11. PRIVACY OF CHILDREN AND STUDENTS
1) We do not collect and store personal information about Children (in this provision, we define Children as minors under 18 years of age) if this information is submitted by a Child without prior parental consent or by the parent or guardian of the Child. If we discover that we’ve unintentionally collected information from a Child in a way that does not meet COPPA and DOPPA requirements, we will delete the information immediately.
2) In accordance with SDPPA, we do not engage in any unlawful conduct in respect of the student data, including the followings:
a) targeted advertising based on a student's information, including state-assigned student identifiers;
b) creating a profile of the student using such information, except in furtherance of K-12 school purposes;
c) selling student data, except under limited circumstances; or
d) absent an exception, disclosing the student data.
If you no longer want to receive our e-mails, offers, updates on our products and services, or other communications, please send a request through the following links [https://clobohealth.com/00042355278] or follow the "unsubscribe" instructions at the bottom of each email or communication. Please note that you cannot unsubscribe from certain correspondence from us, including certain messages relating to your use of the Website.
You can lodge complaints about our way of processing your personal data with the data protection supervisory authorities of your country of residence(e.g., The Consumer Protection Unit of the Department of Justice for Delaware residents).
For further information and inquiry, contact:
Publication Date: 2022,04,01
Effective Date: 2022,04,01
If an operator is covered by DOPPA, it must provide a policy that identifies:
the types of personally identifiable information being collected;
the categories of third parties with whom the operator may share such information;
a procedure for a user to review and request changes to that user's information;
the effective date of the policy; and
how the operator will notify users of changes to the policy.