Privacy Policy

Please read this Privacy Policy carefully to understand how RadX, along with their affiliates and joint ventures, will handle your personal information. Each term of this Policy is significant. If you do not agree with the processing of your personal information as outlined in this Policy, we reserve the right, at our sole discretion, to determine whether to provide or continue providing services to you, unless we are legally obligated to do so or otherwise required to engage with you.

1. About Us

RadX is a revolutionary radiographic positioning guide. This mobile application provides users with approximate exposure information and basic positioning instructions for various body areas, enhancing both efficiency and accuracy in radiographic procedures.

2. Information Officer

The contact details of the Practice’s Information Officer are as follows:

Name: Varushan Govender

Email: info@radtechdigital.co.za

Tel: +27 72 612 8488

3. Definition of Terms

"Data Subject" refers to the natural or juristic person to whom personal information relates, such as an individual client, customer or a company that supplies the organization with products or other goods.
"Personal information" refers to information relating to identifiable, living, natural persons and where it is applicable, an identifiable, existing juristic person, including, but not limited to—
  1. information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
  2. information relating to the education or the medical, financial, criminal or employment history of the person;
  3. any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
  4. the biometric information of the person;
  5. the personal opinions, views or preferences of the person;
  6. correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
  7. the views or opinions of another individual about the person; and
  8. the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person;
and “information” has a similar meaning unless the context requires otherwise.
"Processing" refers to any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including –
  • the collection, receipt, recording, organization, collation, storage, updating or modification, retrieval, alteration, consultation or use;
  • dissemination by means of transmission, distribution or making available in any other form; or
  • merging, linking, as well as restriction, degradation, erasure or destruction of information.
"Consent" means any voluntary, specific and informed expression of will in terms of which permission is given for the processing of personal information.
"POPIA" means the Protection of Personal Information Act (Act 4 of 2013) and Regulations made in terms thereof.
"We" / "us" refers to the owners and directors of the RadX Application.
"You" / "your" refers to the data subject (i.e. the person or entity) whose personal information is in the possession of or under the control of or processed on the Application.

4. Application of the Privacy Policy

This Privacy Policy applies to personal information that we hold or control, including information we collect from you or that you provide to us, such as when you submit information through the RadX Application. It outlines how we collect your personal information, the types of information collected, the reasons for collecting it, the circumstances under which it may be shared with others, the security measures we have put in place to protect your personal data, and your rights to access and correct the information we possess or control.

5. Our Commitment

We recognize that your personal information is valuable to you, and we understand any concerns you may have about sharing it. Your privacy and the security of your information are just as important to us. That's why we want to ensure you are fully informed about how your information will be processed.

We are committed to maintaining the confidentiality of your personal information, as required by law. Our business practices are designed to comply with all legal obligations to protect and preserve the confidentiality of your personal data. We take our responsibility to safeguard your personal information seriously and have implemented various processes to ensure that your information is handled appropriately and securely.

6. Privacy Principles

We adhere to the following principles to safeguard your privacy:

  • We collect only the personal information necessary for our purposes.
  • Your personal information is used solely for the purposes outlined in this Privacy Policy unless you are informed otherwise and provide your consent, if required.
  • We do not retain your personal information longer than necessary.
  • Except as stated in this Privacy Policy or as otherwise agreed with you, we do not share your personal information with third parties.

7. Third-Party Information

Before providing personal information about any other person or entity to us, you must ensure that you have their consent and that they are comfortable with you sharing their information, unless you are legally permitted to do so without consent. You should also make sure they read this Privacy Policy and understand how we will use and disclose their information. By providing us with information about another person or entity, we assume that you have obtained their consent.

8. Collection of Your Personal Information

We obtain personal information directly from you when you register, log into the RadX Application, or provide information to us. Depending on the circumstances, we may also collect information from other sources, such as a regulator, a credit bureau, public records, or when you make information publicly available. The information we request from you is essential to provide you with the best services.

9. Processing of Personal Information

The processing of your personal information is permitted by various laws, including the Protection of Personal Information Act 4 of 2013 (POPIA). We will only process your personal information—whether that involves collecting, using, storing, or disclosing it—in accordance with the law or with your consent. Personal information will be processed only for specific, explicitly defined, and legitimate purposes. We will inform data subjects of these purposes before collecting or recording their personal information.

We will ensure that personal information under its control is processed:

  • in a fair, lawful and non-excessive manner, and
  • only with the informed consent of the data subject, and
  • only for a specifically defined purpose.

10. Processing Limitations

Personal information will not be processed for a secondary purpose unless that processing is compatible with the original purpose. Therefore, where we seek to process personal information for a purpose other than the original purpose for which it was originally collected, and where this secondary purpose is not compatible with the original purpose, we will first obtain additional consent from the data subject.

We will under no circumstances distribute or share personal information between separate legal entities, associated organizations or with any individuals that are not directly involved with facilitating the purpose for which the information was originally collected. Where applicable, the data subject must be informed of the possibility that their personal information will be shared with other aspects of the organization’s business and be provided with the reasons for doing so.

11. Consent

If you consent to us processing your personal information, you may withdraw your consent at any time. However, this will not affect any processing of personal information that has already taken place. Upon withdrawing your consent, we will process your personal information only as permitted by law. If it is reasonable and lawful under the circumstances, we may also terminate our relationship with you.

12. Objections to Processing

In certain instances, you may object to the processing of your personal information, if it is reasonable to do so. This must occur on the form prescribed by POPIA. However, this does not affect the personal information already processed. If you object and we agree with your objection, your personal information will only be processed as provided for in the law. If you exercise this right and, if the circumstances make it reasonable and lawful for us to do so, we may terminate our relationship with you.

13. Purpose of Processing Your Personal Information

We generally process your personal information for the following purposes:

  • To ensure compliance with the law, including administration, billing, and collecting payments from relevant funders, clients, users and/or responsible entities.
  • For communication purposes.
  • For maintaining records.
  • For employment-related matters concerning employees and other practitioners.
  • For reporting to individuals and entities as required and authorized by law or by you.
  • For historical, statistical, and research purposes.
  • For verification purposes.
  • For enforcing our rights.
  • For any other lawful purpose related to our business activities.

We do not use your personal information for commercial purposes.

14. Disclosure of Your Personal Information

To provide our services adequately, we will share only relevant personal information, as necessary under the circumstances, with businesses, employees or others.

Relevant personal information of other individuals and entities may also be shared with our professional advisers, auditors/accountants, funders, regulators, relevant public and private bodies, law enforcement agencies, and the RSSA. This information will be shared only as permitted by law or as otherwise agreed with the relevant parties.

We expressly reserve the right to transfer any and all personal information in our possession or control, without limitation, to a purchaser or other successor in interest in the event of a merger, restructuring, reorganization, dissolution, or other sale or transfer of the business or some or all of its assets.

15. Record-Keeping

We retain records of your personal information for as long as necessary to fulfil lawful purposes in accordance with the law. This includes fulfilling your requests, providing services, complying with legal obligations, resolving disputes, enforcing agreements, and serving as proof. These records may be kept in electronic format. Additionally, we may retain your personal information for historical, statistical, and research purposes, in compliance with legal provisions.

16. Sending Information Across the Borders of the Republic of South Africa

We process and store your information within the Republic of South Africa, including in cloud-based systems that comply with POPIA requirements to protect your privacy. If we need to share your personal information with a third party in another country, we will obtain your prior consent unless the information can be lawfully provided to that third party without your consent.

17. Security Safeguards

We are dedicated to ensuring the security of your personal information to protect it from unauthorized processing, access, loss, damage, or destruction. We regularly review and update our information protection measures to align with industry best practices and maintain the security, integrity, and confidentiality of your information.

We acknowledge the inherent risks associated with the electronic transfer and storage of personal information. To mitigate these risks, we will ensure that all paper and electronic records containing personal information are securely stored and accessible only to authorized individuals.

Access to your personal information is restricted to employees and service providers who need it to perform their functions and provide services to us. All new employees will be required to sign employment contracts that include terms governing the use and storage of employee information. These contracts will contain confidentiality clauses to mitigate the risk of unauthorized disclosures of personal information for which the organization is responsible. For existing employees, after the necessary consultation process, they will be required to sign an addendum to their employment contracts that includes the relevant consent and confidentiality clauses.

Any operators and third-party service providers will be required to enter into service level agreements with the organization. These agreements will reflect a mutual commitment to POPIA compliance and the lawful processing of any personal information pursuant to the agreement.

In the event that your personal information is unlawfully accessed, we will notify you and the Information Regulator, in accordance with legal provisions.

18. Right to Access your Personal Information

You have the right to access your personal information, subject to any restrictions imposed by legislation. You may request access to the information we hold or control, as well as information about third parties to whom we have disclosed your information. To exercise this right, please complete and submit the prescribed form to our Information Officer. There may be costs associated with this request. You can obtain the relevant form and details about any applicable charges from the Information Officer.

19. Accuracy of Your Personal Information

It is important for us to maintain accurate information about you, as it can impact communication and, if applicable, your health. Therefore, you should inform us promptly of any changes to your information.

If you find that the information we have about you is incorrect or outdated, you may request a correction or deletion by contacting our Information Officer. We will ensure that the provision of a facility for data subjects who want to request the correction or deletion of their personal information. Kindly note that we will only correct or delete information if we agree it is inaccurate or should be removed. Also note that it may not be possible to delete all information if there is a legal obligation to retain it.

Please contact the Information Officer to discuss how we can assist with your request. If we make any corrections to your information that affect decisions made or to be made about you, we will inform any persons to whom the information was previously disclosed, if they need to be aware of the changes.

When personal information is collected or received from third parties, we will take reasonable steps to ensure its accuracy. This may involve verifying the information directly with the data subject or through independent sources.

20. Marketing of Products and Services

If you have provided consent, we may occasionally notify you, either electronically or otherwise, about additional products and services we offer that may be useful or beneficial to you. You can withdraw your consent and opt out of receiving such information at any time. Where applicable, we will include a link to unsubscribe from any of our electronic newsletters or related marketing activities.

21. Changes to this Policy

We reserve the right, at our sole and absolute discretion, to revise or supplement this Privacy Policy from time to time to reflect changes in our business or the law. Updated versions of the Privacy Policy will be published on our Application. Any revised Policy will be effective as of the date it is posted on the RadX Application, so please refer to the Application regularly for the latest version. It is your responsibility to review any changes before continuing to use our services. If we make a material change to this Policy, we will notify you through a notice on the RadX Application, and you will be provided with a link or access to the new Policy. If there is a significant change in how we use your personal information, we will offer you the opportunity to opt out of such new or different uses. If you have any questions about this Policy, please contact our Information Officer.

22. Complaints Procedure

All inquiries, requests, or concerns regarding this Policy or the processing of your personal information should be directed to the Information Officer. If you believe that we are processing your personal information in violation of this Privacy Policy or the law, please contact the Information Officer immediately.

23. Disciplinary Action

When a POPIA complaint or infringement investigation has been finalized, we may recommend appropriate administrative, legal, and/or disciplinary actions against any employee reasonably suspected of being involved in non-compliant activities as outlined in this policy.

In cases of ignorance or minor negligence, the organization will provide additional awareness training to the employee. However, any gross negligence or willful mismanagement of personal information will be treated as serious misconduct, which may result in the employee’s summary dismissal. Disciplinary procedures will be initiated if there is sufficient evidence to support the employee’s gross negligence.

24. Laws applicable to this Privacy Policy

This Privacy Policy is governed by the laws of the Republic of South Africa.