a) What personal information do we collect about you?
We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our medical, pharmaceutical or other services or as a result of your relationship with one or more of our staff and partners.
The personal information that we process includes:
Basic information, such as your name (including name prefix or title), your job, your relatives or other basic information that could enhance our service delivery to you.
Contact information, such as your postal address, zip code, email address and phone number(s), IP address.
Health related information, such as information concerning your health when you report a problem with our website or services offered by us.
Financial information, such as payment-related information.
Technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically.
Information you provide to us for the purposes of attending meetings and events, including access and dietary requirements, as might be organized either by us or any of our partners.
Identification and background information provided by you or collected as part of our business acceptance processes.
Personal information provided to us by or on behalf of our partners or generated by us in the course of providing services to them, which may include special categories of data.
Any other information relating to you which you may provide to us.
c) How we obtain your personal information
We collect information from you as part of our business acceptance processes, and about you and others as necessary in the course of providing medical/pharmaceutical services.
We collect your personal information while monitoring our technology tools and services, including our websites and email communications sent to and from GoMed.
We gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff or registering on one of our digital platforms or applications.
We may collect or receive information about you from other sources, such as keeping the details we already hold for you accurate and up to date using publicly available sources.
d) How we use your personal information
GoMed collects and processes personal information about you in a number of ways, including through your use of our website and in the provision of services by us. We use that information:
To improve this website, including auditing and monitoring its use.
To provide and improve our services to you and to our partners.
To provide information requested by you or maintain other communications with you.
To promote our or our affiliates’ current products and/or services, new services or promotions that we are developing, including sending medical/pharmaceutical updates, publications, details of events and opportunities that may be vital to you.
To manage and administer our relationship with you and our partners.
To fulfill our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims.
To communicate to you about job or career opportunities about which you have inquired.
To deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, and online. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference centers for you to manage your information and marketing preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important service information related to your accounts and subscription.
e) On what basis we use your personal information
We use your personal information on the following basis:
To provide services or conduct our business operations.
For the establishment, exercise or defense of legal claims or proceedings.
To comply with legal and regulatory obligations.
For legitimate business purposes. Please see Paragraph d) above for more detail.
f) How long we keep your personal information
Your personal information will be retained in accordance with our global data retention policy which categorizes all of the information held by GoMed and specifies the appropriate retention periods for each category of data. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, standard practice and GoMed’s business purposes. When this standard information retention period elapses, we securely delete and destroy the retained information.
g) Who we share your personal information with
We are a fast growing online marketplace for licensed pharmaceutical brands in Nigeria. GoMed is an initiative of a Finland company, with a Nigeria subsidiary and any information that you provide to us may be shared with and processed by our GoMed teams around the world, mailing offices, as well as our affiliates if necessary for the provision of services, account administration, sales and marketing, customer and technical support, and business and product development. All our employees and contractors are required to follow our data protection and security policies when handling personal data.
We may also share your personal information with our partners, when necessary, in accordance with contractual arrangements in place with them, including:
Our professional advisers and auditors
Suppliers to whom we outsource certain support services such as word processing, translation, software, system, platform support and document review; direct marketing services, cloud hosting services; advertising; and order fulfillment and delivery.
IT service providers to GoMed
Third parties engaged in the course of the services we provide to clients and with their prior consent, such as lawyers, and technology service providers like data room and case management services
Third parties involved in hosting or organizing events or seminars.
Our third-party service providers are not permitted to share or use personal data we make available to them for any other purpose other than to provide services to us.
Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements, we will use reasonable endeavors to notify you before we do this, unless we are legally restricted from doing so.
Specifically, certain items you might order from our vendors are regulated products for which vendors are obligated to keep a dispensary log under the provisions of Dangerous Drug Act, Food and Drug Act, National Agency for Food and Drug Administration and Control Act, National Drug Formulary and Essential Drugs List Act, National Drug Law Enforcement Agency Act, Indian Hemp Act, Pharmacists Council of Nigeria Act, Poison and Pharmacy Act, National Drug Policy or other drugs and food control laws and regulations in Nigeria.
If in the future we re-organize or transfer all or part of our business, we may need to transfer your information to new GoMed entities or to third parties through which the business of GoMed will be carried out.
We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
h) How we protect your personal information
We use a variety of technical and organizational measures to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
i) Which countries we transfer your personal information to
j) Your rights regarding your personal information
The ECOWAS Act on Personal Data Protection and other applicable data protection instruments provide certain rights for data subjects.
You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information, to stop unauthorized transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organization. You may also have the right to lodge a complaint in relation to GoMed’s processing of your personal information with a local supervisory authority.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. When we receive your request, we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for regulatory purposes).
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve some of the purposes set out above (see Paragraph d)) or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
Use Of GoMed Website
A number of facilities on our website invite you to provide us with personal information, such as the vacancy application facility in the career section of our website and our email queries facilities. The purpose of these facilities is apparent at the point that you provide your personal information and we only use that information for those purposes.
Marketing and other emails
We use personal information to understand whether you read the emails and other materials, such as medical/pharmaceutical publications, that we send to you, click on the links to the information that we include in them and whether you visit our website after you click on that link (immediately or on future visits). We do this by using software that places a cookie on your device which tracks this activity and records it against your email address. You are at liberty to manage or remove the cookie. Removal of this cookie will not affect your experience on our websites.
If you receive marketing communications from us and no longer wish to do so, you may unsubscribe at any time.
Meetings, events and seminars
We collect and process personal information about you in relation to your attendance at an event or seminar organized by GoMed, its affiliates or partners. We will only process and use special categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other medical or regulatory obligations we may have. We, our affiliate or partners may share your information with IT and other service providers or business partners involved in organizing or hosting the relevant event.
Legal and other services
We collect, create, hold and use personal information in the course of and in connection with the services we provide to our partners. We process identification and background information as part of our business acceptance, finance, administration and marketing processes, including anti-money laundering, anti-drug abuse, conflicts, reputational and financial checks. We will also process personal information provided to us by or on behalf of our Partners for the purposes of the partnership we have with them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that partnership. Please also see Paragraphs g) and i).