set out the basis on which any Personal Information (as defined in paragraph 2.2 below) that we collect
from you, or that you provide to us, will be used, stored and processed by us.
protect or otherwise handle your Personal Information.
- Any references to "we", "us" or "our" in this Privacy
Policy shall be to Panda Technology Holdings Limited, and shall include, where applicable, our
affiliates and subsidiaries. References to "user", "you" or
making use of the App to render their services to users or to contribute content, advice or information.
- We are the "responsible party" or "controller" for purposes of applicable data
protection legislation in respect of all your Personal Information that you submit to us via our
website(s), mobile application(s) and any other website(s) or mobile application(s) of ours that you may
access (the "Platforms") and/or that may be collected by us through any correspondence
and/or communication with you.
- This Policy applies to Personal Information collected by us in connection with our services and these
Platforms, information collected through direct marketing campaigns, sweepstakes and competitions, and
through our Platforms, branded pages on third-party platforms and websites accessed or used through such
websites or third-party platforms which are operated by or on behalf of us.
- This Policy does not apply to the practices of third parties (including, without limitation, their
websites, platforms and/or applications) which we do not own or control or individuals that we do not
manage or employ. These third-party platforms may have their own privacy policies and terms and
conditions and we encourage you to read them before using those third-party platforms. Please note
paragraph 11 below as it deals with Personal Information you submit to third parties.
INFORMATION WE MAY COLLECT ABOUT YOU
- We collect your Personal Information, so that we can provide our products and services to you. We only
collect as much data as we need. We will always collect Personal Information in a fair, lawful and
reasonable manner to ensure that it protects your privacy and we will process your Personal Information
based on legitimate grounds in a manner that does not adversely affect you.
- We collect data in different ways on our Platforms, such as when you directly give us your Personal
Information. This includes when ―
- you visit our Platforms;
- you provide certain Personal Information (such as your name, address, telephone and e-mail
address) by filling in forms or by corresponding with us;
- you make purchases of products and services via our Platforms;
- you register to receive marketing or correspondence from us;
- you request information to be sent to you; and/or
- you provide feedback to us.
- When you interact with our Platforms, we may automatically collect technical data about your equipment,
browsing actions and patterns. Through analytics, we may use anonymised aggregated data such as
statistical or demographic data.
- In limited circumstances, we may collect Personal Information from third parties or from public sources,
such as from external services providers contracted by us to maintain certain sections of these
Platforms. Such third parties may also include our affiliates and subsidiaries, regulatory bodies, other
companies providing services to us and information we access where we make use of publicly available
sources of information.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect your Personal Information, so that we can provide our
products and services to you. We only collect as much data as we
need. We will always collect Personal Information in a fair,
lawful and reasonable manner to ensure that it protects your
privacy and we will process your Personal Information based on
legitimate grounds in a manner that does not adversely affect
We collect data in different ways on our Website, such as when
you directly give us your Personal Information. This includes
- you visit the Website;
you provide certain Personal Information (such as your name,
address, telephone and e-mail address) by filling in forms
or by corresponding with us by e-mail or otherwise;
you make purchases of our products and services via our
- you register for e-mail alerts on the Website;
- you request information to be sent to you; and
- you provide feedback to us.
When you interact with our Website, we may automatically collect
technical data about your equipment, browsing actions and
patterns. Through analytics, we use anonymised aggregated data
such as statistical or demographic data.
In limited circumstances, we may collect Personal Information
from third parties or if publicly available, such as from
external services providers contracted by us to maintain certain
sections of this Website. Such third parties may also include
our affiliates and subsidiaries, regulatory bodies, other
companies providing services to us and information we access
where we make use of publicly available sources of information.
PURPOSE OF YOUR INFORMATION
- We may use the information, including the Personal Information we hold about you, for the following
- to process and facilitate payments you make via our Platforms;
- to verify and keep a record of your identity;
- to ensure that the content on our Platforms is presented in the most effective manner for you
and for your device;
- to monitor and analyse the conduct on the Platforms to ensure compliance with laws, reduce the
likelihood of fraud and other risk-prevention purposes;
- for internal business purposes such as generating statistics and developing our strategic and
- to provide you with information on our Platforms that you request from us and/or to contact you
about products and services that you request from us;
- to market our products and services which we feel may interest you, where you have consented to
being contacted for such purposes;
- to carry out statistical and marketing research and for forecasting;
- to allow you to participate in interactive features of our Platforms, when you choose to do so;
- to carry out any contracts that may form between us;
- to generate reports and conduct statistical analysis about the queries you make using the
- to respond to any queries you make;
- to notify you about changes to our Platforms and/or products and services; and/or
- to improve the products and services, we offer – for example you may be asked to complete
an online survey or we may employ tools to analyse the Platforms to enhance our products and
- We may also use the information provided by you to ―
- enforce agreements and terms and conditions between us, monitor user activity, and more
effectively manage traffic on the Platforms;
- provide customer services; and
- assist you with technical difficulties.
WHAT ARE THE LAWFUL GROUNDS THAT WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
- When we process, collect or store your Personal Information, we do so on the following
- where it is necessary to process your Personal Information in connection with the
performance of a contract that we have with you, including any terms and conditions you
agree to when making use of our Platforms;
- where we are required to use your Personal Information to comply with our legal
obligations, a request from a regulator or court of law or as otherwise permitted by
- to pursue our legitimate interest, provided that your interests and fundamental rights
or freedoms do not override those interests; and
- for any other purpose that you have agreed to with us where you have given your explicit
consent for specific forms of processing of your Personal Information, which consent you
may decline or revoke at any time.
- Please note that we may process your Personal Information without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
ACCESSING PANDA VIA YOUR EMPLOYER OR ANOTHER BENEFIT PROGRAMME
- Your employer, insurer or a similar or related institution may give you access to Panda. To
facilitate your access, they or we may need to request additional Personal Information from you
to allow us to onboard you to our Platforms and to allow them to verify your eligibility for
- These organisations do not have access to the content or Personal Information you may share with
or via Panda unless you choose to disclose this to them.
- The types of Personal Information that may need to be collected and processed by Panda or by
these organisations include your name, contact information, birth date, relationship to the
organisation and the name of the organisation through which you are accessing Panda.
SHARING OF YOUR PERSONAL INFORMATION
- We will not use your Personal Information for any purpose (other than as stated in
paragraph 4 above) without your consent. We will not use or disclose your Personal
Information to third parties without your consent, unless the use or disclosure is ―
- required in order to comply with applicable law, an order of court or legal process
served on us; and/or
- disclosure is necessary to protect and defend our rights or property.
- We will be entitled to disclose your Personal Information to our affiliates, agents, advisors,
employees and/or third-party service providers and suppliers who assist us to interact with you
via our Platforms, mobile communications and/or email, and thus need to know your Personal
Information in order to assist us in conducting our business and communicating with you properly and efficiently. We will
ensure that all such employees and/or third-party service providers having access to your
Personal Information are bound by appropriate and legally binding confidentiality and non-use
obligations in relation to your Personal Information.
- We may also provide information to third party service providers who process data on our behalf
to help run some of our internal business operations including :
- email distribution;
- the facilitation of payment, billing and medical aid claim processes;
- information technology services;
- testing and analytics services;
- technical services (e.g., providers of data storage, data backup, and CRM systems);
- security researchers;
- entities involved in dispute resolution (such as an arbitrator or an opposing party);
- entities involved in potential or actual significant corporate transactions or events;
- governmental entities; and
- customer services
- You understand that we may disclose or share Personal Information with third parties as
outlined above to operate the Platforms and render our products and services. If you are
concerned about these arrangements, you should not use the Platforms.
- On rare occasions, we may be required to disclose your Personal Information due to legal or
regulatory requirements. In such instances, we reserve the right to disclose your Personal
Information as required in order to comply with our legal obligations, including but not limited
to complying with court orders, warrants, subpoenas, service of process requirements or
- We may also disclose data about our users to law enforcement officers or others, in the good
respond to claims that any content violates the rights of third-parties, or protect the rights,
property, or our personal safety or the personal safety of our employees, clients or the general
DATA RETENTION AND STORAGE
- We will not retain your Personal Information longer than the period for which it was originally
required, unless we are required by law to do so, or you consent to us retaining such
information for a longer period. Where your information is no longer required, we will ensure it
is disposed of in a secure manner and, where required by applicable law, we will notify you when
such information has been disposed of.
- Copies of correspondence sent from our Platforms, that may contain your Personal Information,
may be stored as archives for record-keeping and back-up purposes.
- We may store your Personal Information using our own secure on-site servers or other internally
hosted technology. Your Personal Information may also be stored by third parties, via cloud
services or other technology, whom we have contracted with to support our business operations.
- If you have questions about the retention of your records, please email us at the email address
set out in paragraph 13.4 below.
PROTECTION OF YOUR PERSONAL INFORMATION
- We are committed to protecting the Personal Information you provide in a variety of ways.
- We will ―
- treat your Personal Information as strictly confidential;
- take appropriate legal, technical and organisational measures to ensure that your
Personal Information is kept secure and is protected against unauthorised or unlawful
processing, accidental loss, destruction or damage, alteration, disclosure or access;
- where legally required, promptly notify you if we become aware of any unauthorised use,
disclosure or processing of your Personal Information; and
- upon your request, promptly return or destroy any and all of your Personal Information
in our possession or control.
- We have put in place procedures to deal with any suspected data security breaches and will
notify you and any applicable regulator of a suspected breach or unauthorised disclosure where
we are legally required to do so.
- We will do our best to protect your Personal Information, and we will use technology that will
help us to do this, however, the transmission of information via the internet is not completely
secure and we cannot guarantee the security of your information transmitted to or via our
Platforms. Any transmission of your information on the Platforms is entirely at your own risk.
Once your information is received by the Platforms, we and/or our third party service providers
shall use strict procedures and security features to try and prevent unauthorised access.
COOKIES AND OTHER INFORMATION
information, and language selections. "Cookies" are small text files
transferred by a web server to your hard drive and thereafter stored on your computer.
- We may use these cookies and similar techniques when you access our Platforms to provide you
with a better experience.
- Cookies enable us to ―
- estimate our Platforms' audience size and usage pattern;
- store information about your preferences, which allows us to customize the Platforms
according to your individual interests;
- speed up your searches; and
- recognise you when you return to the Platforms.
certain features of the Platforms.
- We acknowledge that we may only use your Personal Information for purposes of direct marketing
(such as sending you email marketing and newsletters) where it is permissible to do so in terms
of applicable data protection legislation.
- We may use your Personal Information to contact you and/or market ourservices directly to you if
you are one of our existing users or where we have your consent to market directly to you.
- If you are an existing user, we will only use such Personal Information of yours that we have
obtained through the provision of our products and services to you, and only in relation to
similar products and services to the ones we previously provided to you.
- We will ensure that you have a reasonable opportunity to object to the use of your Personal
Information for direct marketing purposes when we collect the Personal Information from you and
in each instance where we may send you direct marketing communications. This will generally be
in the form of an opt-in function and in the form of unsubscribe and opt-out functionalities.
- We will not use your Personal Information to send you direct marketing communications if you
have requested not to receive it. If you request that we stop Processing your Personal
Information for direct marketing purposes, we shall do so. We encourage you to use the forms and
links provided for this purpose in the marketing materials sent to you.
- We may use third-party service providers to monitor our users’ interests. In addition, the
Platforms may occasionally contain links to third-party websites. If you click on the links to
third-party websites, you leave the Platforms.
- We are not responsible for the content of these third-party websites or for the security of your
Personal Information when you use the third-party websites. These third-party service providers and
third-party websites may have their own privacy policies governing the storage and retention of your
Personal Information that you may be subject to.
third-party providers and third-party websites. We recommend that when you enter a third party's
and protect your Personal Information.
- By using our Platforms, you agree that we are not liable for any of the following ―
- the content, security, operation, use, accuracy or completeness of any such third-party
platforms; or the products or services that may be offered or obtained through them; or the
accuracy, completeness, or reliability of any information obtained from a third-party platform;
- the ownership or right of use of any licensor of any software provided through any third-party
- any content featured on a third-party platform that is accessed through the links found on our
- any failure or problem that affects the products or services of a third-party platform, for
example any telecommunication service provider, internet service provider, electricity supplier,
local or other authority.
YOUR RIGHTS IN RELATION TO OUR USE OF YOUR PERSONAL INFORMATION
- Subject to certain exceptions and your jurisdiction, you have rights under applicable data
protection law in relation to our use of your Personal Information, including the right
- review, or request access or copies of your Personal Information which is within our
custody and control together with details about how we use that information. If you
think any of the Personal Information that we hold about you is inaccurate, you may also
request that we correct or rectify it;
- require us to stop processing your Personal Information in certain circumstances;;
- request that we delete or erase Personal Information in certain circumstances (such as
in accordance with local data retention legal obligations);
- withdraw any consent to processing that you have given us and prevent further processing
if there is no other legitimate ground upon which we can process your Personal
- restrict processing: you can require certain Personal Information to be marked as
restricted for processing in certain circumstances;
- data portability i.e. you can ask us to transmit the Personal Information that you have
provided to us to a third party;
- object to automated decision-making, including profiling; and
- lodge a complaint with the relevant data protection regulator if you think we are in
breach of any applicable data protection legislation.
- In relation to all of these rights, please email us at the email address set out in paragraph
13.4 below. Please note that we may, where permitted under applicable law, charge a small
administrative fee and/or request proof of identity. We will respond to your requests within all
- In certain circumstances (for example where required or permitted by law), we might not be able
to provide you with access to some of your Personal Information, but where appropriate we will
notify you of the reasons for this.
- You may request access to the Personal Information that we collect about you by sending an email
to us at firstname.lastname@example.org
- You warrant that all information (including Personal Information) that you provide to us is
accurate, truthful and current information, and not to impersonate or misrepresent any person or
entity or falsely state or otherwise misrepresent your affiliation with anyone or anything.
Failure to adhere to this requirement will entitle us to, among other things, terminate your use
of the Platforms.
- You acknowledge that we may verify your identity and your Personal Information through an
automated email verification process and/or with third party service providers.
protection legislation which may apply in your jurisdiction. Therefore, all provisions of this
provisions of data protection legislation are complied with.
AUTOMATED DECISION MAKING
We do not make use of automated decision-making or profiling.
INTERNATIONAL DATA TRANSFERS
- We may, from time to time, transfer, store or host your Personal Information outside of your
jurisdiction. Should your Personal Information be transferred outside your jurisdiction, we
shall ensure that at least the same level of data protection will be applied in the country
where the data is being processed and/or that we and the recipient at all times act in
compliance with applicable privacy laws.
- We will at all times ensure that appropriate security safeguards are in place to secure and
protect such Personal Information and take measures to ensure that the Personal Information
handled will receive the level of protection as required by all applicable laws.
- An example of where your Personal Information may be transferred to another country is where a
service provider whom we rely on hosts your Personal Information in a foreign country.
compliance with applicable law. We may send you a notice regarding material changes to this Privacy
grouped together or linked grammatically, severable from each other. Any provision or clause of this Privacy
which is or becomes unenforceable in any jurisdiction, whether due to voidness, invalidity, illegality,
or for any other reason whatever, shall, in such jurisdiction only and only to the extent that it is so
unenforceable, be treated as pro non scripto (as if not written herein) and the remaining provisions and
WHOLE WHOLE AGREEMENT
These Terms and Conditions, as read with the user and professionals’ terms and conditions, constitute
entire and only agreement between Panda and you in respect of the matters contained herein and supersedes
all prior or contemporaneous agreements, representations, warranties, and understandings concerning this App
You have the right to lodge a complaint in respect of our Processing of your Personal Information. You can
the office of the regulator in your jurisdiction.
HOW TO CONTACT US
Last updated on 10 May 2022