Be.Well by Slade360° Privacy Policy

1. What is Personal Information

“Personal Information” is the information that identifies and relates to you, or to other individuals who also benefit from our Services, such as your dependents and can include sensitive personal data. “Sensitive Personal Data” includes information revealing your race, health status, ethnic social origin, belief, genetic data, marital status, your sex or sexual orientation.

2. What types of personal information will be collected?

We will collect and process various types of personal data about you, such as:

• General information such as your name, contact details (email address and telephone numbers), date of birth and gender
• Health ID and insurance information
• Location information
• IP addresses when visiting web pages with cookies
• Usage data and preferences on the platform

3. How will we obtain your personal information?

We will collect and use the personal information that you provide to us and that we receive about you from different sources for a number of purposes and with your explicit consent unless applicable laws and regulations do not require us to obtain your explicit consent. The sources include:

• You directly when you provide it to us during registration
• As we are required to collect your Personal Information as a condition for providing our Services
• From third-party sources such as health insurance providers and healthcare facilities with your consent
• Automatically as you navigate and use our platform

4. How will we use your personal information?

We will use your Personal Information for the following purposes:

• To provide and maintain our Services
• To verify your identity and health insurance coverage
• To connect you with healthcare providers and facilities within your network
• To send you notifications about your appointments and bookings
• To provide customer support
• To improve and personalize our Services
• To communicate with you about updates, promotions, and new features (with your consent)
• To comply with legal and regulatory requirements

5. Legal grounds for processing your personal information

We will process your Personal Information on the following legal grounds:

1. Performance of a contract - Processing is necessary to provide the Services you have signed up for
2. Consent - Where you have provided explicit consent for specific processing activities
3. Legitimate interests - To improve our Services and maintain security
4. Legal obligation - To comply with applicable laws and regulations

6. Disclosure of Information

Your personal information may be disclosed where it is necessary for providing you with the Services you are entitled to. We shall assess and review each application for information and may decline to grant such information to the requesting party. Where granted, only minimum and necessary personal information may be shared. Sensitive information (i.e. medical information related to you) will not be shared without seeking your express consent.

We may disclose your Personal Information to:

1. Healthcare providers and facilities within your insurance network
2. Health insurance providers to verify coverage and benefits
3. External third-party service providers, such as IT systems, support and hosting service providers
4. Our regulators and governmental authorities where necessary to comply with legal obligations
5. External professional advisors such as auditors, consultants, and lawyers

7. International Data Transfers

Due to the nature of the Service, the data that we collect from you may be transferred to and stored at a destination outside Kenya. Your Personal Information can be shared with or accessed by parties located in other countries outside Kenya that have a different data protection regime from Kenya.

In any case where we transfer your Personal Information outside Kenya, we will conduct the transfer in accordance with applicable data protection laws and ensure that there are appropriate safeguards in place with respect to the protection of your Personal Information.

8. Retention of Personal Information

1. We will only retain your Personal Information for as long as is necessary to provide you with the Services and comply with legal, accounting, or reporting requirements.
2. We ensure that proper procedures are in place to manage your Personal Information and to remove or archive it when necessary.
3. We will delete your personal information once our retention period of 6 years after your last use of our services expires.
4. Anonymized information that can no longer be associated with you may be held indefinitely for analytics and improvement purposes.

9. Your Rights

Under data protection laws you have certain rights in relation to the Personal Information that we hold about you. You may exercise these rights at any time by contacting us using the details set out in the “Contact Us” section below.

Your rights include:

1. The right to information - You are entitled to be informed of the purpose to which your personal information is to be put.
2. The right to access your Personal Information - You are entitled to a copy of the Personal Information we hold about you.
3. The right to object to or restrict processing - You are entitled to object to our processing of your Personal Information or ask us to stop using your Personal Information.
4. The right to rectification - You are entitled to correct, amend, or update the Personal Information we hold about you.
5. The right to erasure - You are entitled to request the erasure of your Personal Information.
6. The right to data portability - You have the right to ask that we provide your Personal Information to you in a commonly used electronic format.
7. The right to object to direct marketing - You are entitled to object to the commercial use of your data.
8. The right to withdraw consent - You have a right to withdraw your consent at any time.
9. The right to lodge a complaint - You have a right to complain to the Office of the Data Protection Commissioner if you believe that any use of your Personal Information by us is in breach of applicable data protection laws.

10. Security of Personal Information

We will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable data protection laws to protect your Personal Information. We use industry-standard security measures including encryption, secure servers, and access controls.

11. Changes to this Policy

We may update this Privacy Policy from time to time to ensure that it remains accurate. Please check back each time that you provide additional Personal Information to us. Where changes to the Policy will have a fundamental impact on the nature of our processing of your Personal Information or otherwise have a substantial impact on you, we will give you sufficient advance notice.

This Privacy Policy was last updated in December 2025.

12. How to Contact Us

If you would like to contact us on any aspect of this privacy policy or have any questions concerning the processing of your Personal Information, you can contact us through the channels below: