Privacy Notice

Dr Ganesh Inc trading as NeuroAxis

NeuroAxis is committed to protecting and respecting your privacy when handling your Personal Information. This Privacy Notice sets out the basis on which any Personal Information we collect from you, or that you provide to us, is used, stored, disclosed, and processed by NeuroAxis. Please read the following carefully to understand our practices regarding your Personal Information, how we will treat it, and your rights in relation to that information. By providing your Personal Information to us or by using our services, website, or other online or digital platforms, you are accepting or consenting to the practices as described in this Privacy Notice.

When we refer to “we”, “us”, and “our”, we mean NeuroAxis and its affiliated entities. Please note that while NeuroAxis operates as a private neurology practice, Dr Ganesh also provides care in hospital settings through her admission rights at selected hospitals. In these contexts, standard hospital procedures and privacy policies may also apply.

1. Your Personal Information

When we refer to Personal Information in this Notice, we mean information relating to an identifiable, living, natural person, as defined in the Protection of Personal Information Act, 2013 ("POPIA"). We may hold and use Personal Information about you as a patient, client, employee, supplier, or in any other capacity, in accordance with applicable privacy and health laws.

Depending on the services you receive from us, this may include Special Personal Information, such as data related to your health. Disclosure of your Personal Information to NeuroAxis is required for the provision of our services unless explicitly indicated as voluntary at the point of collection.

2. When Do We Collect Your Personal Information?

We may collect information about you when you:

• Schedule an appointment or consultation at our private practice, or are seen within our affiliated hospitals where Dr Ganesh holds admission rights.
• Are referred by a doctor or another organisation for neurology services.
• Visit our website.
• Apply for a position with us as part of our recruitment process.
• Enquire about our services.
• Use or request to use any of our online services.
• Fill in a form or survey provided by us.
• Carry out a transaction on our website.
• Participate in a competition, promotion, or marketing activity.
• Make a payment to us.
• Contact us by email, telephone, or social media.
• Participate in interactive features on our website.

Please note that, in our effort to continually improve our services, calls to NeuroAxis or its affiliated entities may be monitored or recorded.

3. Lawful Basis for Processing

To process your Personal Information in accordance with POPIA, we must establish a lawful basis for doing so. Our processing is based on at least one of the following grounds:

• Your consent
• Processing necessary for the performance of a contract or to comply with a legal obligation
• Processing necessary for the protection of our and your legitimate interests.

In addition, Special Personal Information (such as health-related data) may be processed if necessary for your proper treatment and care, the administration of our practice, or for related insurance and payment processes.

In certain circumstances permitted by law (for example, by court order or when non-disclosure represents a serious threat to public health), we may be required to disclose your Personal Information.

4. The Security and Storage of Your Personal Information

Your Personal Information will be kept confidential and secure and will, unless you agree otherwise, only be used for the purposes for which it was collected and in accordance with this Privacy Notice, POPIA, and applicable health laws.

Organisational and Technical Security Measures

• We have implemented appropriate organisational and technical security measures to prevent unauthorized access or unlawful processing of Personal Information and to safeguard against loss, destruction, or damage.
• We monitor our information systems to ensure robust ongoing security.
• All Personal Information you provide to us is stored securely.
• If you are provided with, or choose, a password to access parts of our website or information systems, you are responsible for keeping that password confidential. Please do not share it with anyone.
• Please note that information transmitted over the internet cannot be guaranteed to be completely secure. Once we have received your information, we use strict procedures and security features to prevent unauthorized access.

At your or your doctor’s request, we may transfer Personal Information—including health information—to you or your doctor via email or instant messaging (including WhatsApp). Similarly, you may choose to provide information to us via these methods. While this may facilitate timely communication, please note that such methods are not the most secure. If you choose to use these channels, you do so at your own risk.

Some risks associated with using instant messaging or email include:

• These platforms may not be monitored by NeuroAxis, as messages are typically sent and received on personal devices.
• Responsibility for safeguarding information transmitted on these platforms rests with both the sender and the recipient.
• Data stored or backed up on these platforms may be processed in jurisdictions outside South Africa until permanently deleted.

5. IP Address Collection

When you access our website, your IP address is automatically collected and stored as part of our usage records. This information helps us understand website usage patterns, including the number of times the website is accessed, the frequency of visits to specific pages, and the timing of these visits. In the event of a security breach, your IP address may be used to identify you through your internet service provider. NeuroAxis takes steps to ensure that IP addresses are processed in a manner that respects your privacy.

6. Transfers of Personal Information Outside of South Africa

Personal Information collected by NeuroAxis may be transferred to, stored at, or processed in destinations outside of South Africa. This may include processing by staff of third-party suppliers or our hospital partners. When such transfers occur, we will take all reasonable steps to ensure that adequate protections are in place, in accordance with POPIA. By providing your Personal Information, you consent to its transfer and processing in these circumstances.

7. Disclosure of Your Personal Information

NeuroAxis may disclose your Personal Information (to the extent necessary) to third parties that support the delivery of our services. The scope of such disclosures may vary depending on whether your care is provided directly by our private practice or within our affiliated hospital settings.

For Our Private Practice:

• Healthcare Providers:
  At NeuroAxis, our clinicians, and allied healthcare providers who are dedicated to delivering high-quality care.
• Billing and Account Recovery:
  We may share your Personal Information with third parties assisting us in recovering payments on outstanding accounts related to services provided at our practice.
• Third-Party Service Providers:
  Your information may be shared with outsourced IT support providers, equipment maintenance personnel, or other vendors required to maintain our systems and support our operations.
• Internal Compliance:
  Should there be an incident or need for review, your Personal Information may be shared with the designated employee responsible for internal reviews and compliance matters.

For Hospital-Based Care:

• Affiliated Hospital Providers:
  When you are treated within our affiliated hospital settings where Dr Ganesh holds admission rights, your care is provided by the hospital’s staff, including doctors, nurses, and allied health professionals. In such cases, standard hospital protocols and privacy policies apply.
• Billing and Administrative Functions:
  For services provided in hospital settings, relevant information may be shared with third parties assisting in billing or account recovery, consistent with the practices of the hospital partner.
• Data Sharing Agreements:
  In certain circumstances, your information may be shared through designated data sharing agreements or health information exchanges. Where applicable, detailed consent and separate privacy notices will be provided.

In all cases, NeuroAxis is committed to sharing only the minimum necessary Personal Information required for the specific purpose and will take reasonable steps to have third parties adhere to confidentiality and security obligations.

8. Your Rights

You have the following rights in relation to your Personal Information, subject to applicable law:

• Right of Access
  You may request details of the Personal Information we hold about you and obtain a copy.
• Right to Rectification
  You have the right to have inaccurate information about you corrected or removed.
• Right to Erasure ("Right to Be Forgotten")
  You may request that certain Personal Information about you be erased.
• Right to Restriction of Processing
  You may request that your Personal Information is processed only for limited purposes.
• Right to Object
  You have the right to object to the processing of your Personal Information in circumstances where such processing is based on public interest or our legitimate interests.
• Right to Information Portability
  You may ask for the Personal Information you have provided to us to be transferred to you or a third party in a machine-readable format.
• Right to Withdraw Consent
  If you have previously provided consent for processing, you may withdraw your consent at any time. Please note that withdrawal will not affect the lawfulness of processing carried out prior to the withdrawal.
• Right Regarding Automated Decisions
  You have the right not to be subject solely to automated processing that produces legal or similarly significant effects on you, unless such processing is necessary for contractual purposes, authorised by law, or based on your explicit consent. NeuroAxis will inform you of such decisions, the legal basis for them, and your rights regarding them.

To exercise any of these rights or if you believe that your Personal Information is not being handled in accordance with this Privacy Notice or applicable laws, please contact us at:

Email: queries@neuroaxis.co.za

9. Changes to Our Privacy Notice

We review our Privacy Policy regularly, and it may be amended from time to time without prior notice. We encourage you to review this Privacy Policy periodically to stay informed of how we protect your Personal Information.

This Privacy Notice was last updated on 3^rd March 2025. All rights reserved.

NeuroAxis Contact Information

NeuroAxis, Suite 2022, Life Vincent Pallotti Hospital, Alexandra Road, Pinelands, Western Cape, 7405

If you have any questions or concerns regarding this Privacy Policy or the processing of your Personal Information, please contact us directly or, where appropriate, the relevant hospital’s privacy office.

For further inquiries or to lodge a complaint regarding the processing of your Personal Information, you may also contact the Information Regulator in South Africa: https://inforegulator.org.za