Privacy Policy
1. Introduction and Scope
This document sets out the Privacy Policy (“Terms”) of Elinkt (“the Company”, “we”, “us”) with registration number 2021/421282/07.
Welcome to Elinkt.
Elinkt provides digital services designed to make important information available when it may be needed most. Our services include Health and Pet Linkt, a QR-code web-based immediate identification service that allows an individual to make selected personal, medical and emergency contact information available through a QR Code.
This Privacy Policy explains how Elinkt collects, uses, stores, protects and, where applicable, shares personal information when you use our services.
For purposes of this Privacy Policy, “Elinkt”, “we”, “us” or “our” refers to the entity responsible for providing the relevant Elinkt service.
“You” or “your” refers to the person whose personal information is being processed, or, where applicable, a person interacting with the Elinkt service.
This Privacy Policy should be read together with the Elinkt Terms & Conditions.
Elinkt is committed to handling personal information responsibly and in accordance with applicable privacy and data protection laws, including the Protection of Personal Information Act 4 of 2013 (POPIA), where applicable. POPIA establishes minimum requirements for the lawful processing of personal information and provides rights to data subjects.
2. Who This Policy Applies To
The Elinkt platform may involve several different types of people interacting with the service.
This Privacy Policy therefore applies, where relevant, to the following roles:
2.1 End User
The End User is the person who creates or owns a Health and/or Pet Linkt profile and whose information is associated with a Health and/or Pet Linkt QR Code.
The End User may provide information such as (and will differ on Health and Pet Link Profiles):
- Name and Surname
- Email address
- Telephone/contact details
- Profile photograph
- Medical conditions
- Medication information
- Allergies or medication allergies
- Blood type
- Blood transfusion restrictions
- Organ donor information
- Emergency contacts
- Healthcare providers
- Medical aid information
- Medical aid broker information
Not every field is necessarily mandatory, and an End User may only provide information relevant to their circumstances
2.2 QR Viewer
A QR Viewer is a person who scans a Health and/or Pet Linkt QR Code.
A QR Viewer does not necessarily need an Elinkt account.
Depending on the configuration of the profile and information made available by the End User, the QR Viewer may be able to view selected information intended to assist with immediate identification and may be provided with options to contact designated people.
2.3 Next of Kin / Designated Contact
A Next of Kin or other designated emergency contact is a person identified by the End User as someone who may be contacted in an emergency or when a pet is found by scanning the Health and/or Pet Linkt QR Code.
Their information may include:
- Name and Surname
- Contact details
- Email address (for the Next of Kin only)
The End User is responsible for providing accurate information and, where appropriate, ensuring that the designated contact is aware that their information has been provided.
2.4 Healthcare Provider
An End User may provide information about healthcare providers such as:
- Doctor
- Oncologist
- Specialist
- Dentist
- Other healthcare practitioner
Such information may be made available through the End User’s Health Linkt profile where the End User has chosen to provide it. This information would differ on a Pet Linkt profile and will require the veterinary practice information.
2.5 Administrator
An Administrator is an authorised person who manages the Elinkt platform.
Administrators may have access to administrative information necessary to operate, maintain, support and secure the service.
Administrator access is subject to role-based permissions and appropriate security controls.
2.6 Retailers, Resellers and Distribution Partners
Where Elinkt products or QR-enabled products are distributed through retailers, resellers or other distribution partners, limited information may be processed for purposes such as product allocation, QR Code management, fulfilment or distribution.
Such organisations should only receive information appropriate to their role and authorised purpose.
3. What Personal Information We Collect
The information collected depends on how you interact with Elinkt.
We do not necessarily collect every category of information described below from every person.
3.1 End User Information
When an End User creates or manages a Health or Pet Linkt profile, we may collect (and will differ on Health and Pet Link Profiles):
- Personal and contact information
- Name and Surname
- Email address
- Telephone number
- Profile photograph
- Other information voluntarily provided by the End User
- Medical information
Where provided by the End User, this may include:
- Medical conditions
- Medication
- Allergies
- Medication allergies
- Blood type
- Blood transfusion restrictions
- Organ donor information
Health information is subject to additional protection under POPIA.
Emergency contact information
This may include:
- Next of Kin
- Alternative emergency contact
- Name and Surname
- Email address
- Telephone/contact details
Healthcare information
This may include:
- Doctor or healthcare provider
- Practice or facility information
- Contact details
- Medical aid and plan information
- Medical aid broker information
4. QR Code Information
Each Health and Pet Linkt profile may be associated with a unique QR Code reference.
The QR Code itself is intended to provide access to the relevant Health and Pet Linkt profile through the Elinkt service.
The system may maintain information relating to:
- QR Code reference
- QR Code status
- Profile association
- Profile Type
- Activation status
- Creation/generation date
- Activation date
- Deactivation date
- Other lifecycle information required to manage the QR Code
5. Information Collected When a QR Code Is Scanned
When a Health or Pet Linkt QR Code is scanned, Elinkt may record information about the scan for purposes including:
- Providing the Health or Pet Linkt profile
- Date and time of scan
- QR Code reference
- Operating the service
- Security and fraud prevention
- Monitoring service activity
- Sending scan notifications where applicable
- Maintaining technical and audit records
- Approximate scan location, where permission has been granted and the functionality is enabled
6. Scan Location Information
Health and Pet Linkt may provide the QR Viewer with an option to allow access to their device location when scanning a QR Code.
If location access is allowed
An approximate location associated with the device performing the scan may be made available to Elinkt and may be included in a notification sent to the End User’s designated Next of Kin, where this functionality is enabled.
If location access is denied
The QR Code scan may still proceed.
No scan location will be provided through the location functionality where the QR Viewer has not granted the required permission.
Important: The location associated with a QR scan refers to the device/person performing the scan, this can include the QR Viewer, End User, or anyone scanning the QR Code.
7. Next of Kin Notifications
Where enabled, a QR Code scan may trigger an email notification to the End User’s designated Next of Kin.
The notification may contain information such as:
End User name
QR Code reference
Date/time of scan
Whether location access was granted
Approximate scan location, where available
A QR Code scan does not necessarily indicate that an emergency has occurred.
The purpose of the notification is to help the designated contact become aware that the QR Code associated with the End User has been scanned.
8. Why We Process Personal Information
We may process personal information for purposes including:
Providing the Elinkt service to:
- Create and maintain profiles
- Provide Health Linkt functionality
- Display information through QR Code scans
- Manage QR Codes
- Enable profile updates
Immediate identification:
To make selected information available when an Elinkt QR Code is scanned, helping a person assisting the End User understand who they are and who may need to be contacted.
Emergency contact functionality:
To enable communication with designated Next of Kin or other emergency contacts.
Security to:
- Protect accounts and profiles
- Verify email addresses
- Use verification processes
- Detect misuse
- Prevent unauthorised access
- Investigate security incidents
Service administration to:
- Manage the Elinkt platform
- Manage Companies, Departments and Profile Types
- Manage QR Codes
- Maintain administrative records
- Provide customer support
Communications to send:
- Verification emails
- Profile update verification emails
- QR scan notifications
- Important service communications
- Support communications
- Other communications permitted by applicable law
Improving the service:
Where permitted, we may use appropriate information to understand service usage, troubleshoot issues, improve functionality and maintain the reliability and security of Elinkt.
9. Medical Information
Health Linkt is designed to allow an End User to voluntarily provide selected medical information that may assist with immediate identification.
This information may include medical conditions, medication, allergies, blood type and other information described in this Privacy Policy.
Because health information is treated as special personal information under POPIA, Elinkt must apply appropriate safeguards and ensure that the processing has an appropriate lawful basis.
Health Linkt does not independently verify the accuracy, completeness or current status of medical information supplied by an End User.
The End User is responsible for keeping their profile information accurate and up to date.
10. How Information Is Made Available Through a QR Scan
The purpose of Health and Pet Linkt is not to make every piece of information held by Elinkt publicly available.
The system should distinguish between:
Information required to operate the service
and
Information intentionally made available through a QR Code profile.
Only information configured for display through the Health and Pet Linkt profile should be presented to a QR Viewer.
11. Email Verification and Profile Security
When an End User creates or updates a profile, Elinkt may use email verification to confirm ownership of the registered email address.
The system may send:
An initial verification email
A confirmation following successful verification
A new verification request following profile changes
These measures are intended to help prevent unauthorised changes to the End User’s profile.
12. Information About Next of Kin and Other Third Parties
An End User may provide personal information relating to another person, such as a Next of Kin or Alternative Contact.
The End User should only provide information that is accurate and appropriate for the intended purpose.
Where appropriate, the End User should inform the relevant person that their information has been provided to Elinkt and explain the purpose for which it may be used.
13. Administrators and Access to Information
Administrative access is required to operate the Elinkt platform.
Administrators may be able to access information depending on their assigned permissions and responsibilities.
Administrative access should be:
- Role-based
- Limited to what is necessary
- Authenticated securely
- Logged where appropriate
- Reviewed periodically
Administrators should not access or disclose End User information except where necessary for authorised business, operational, support, security or legal purposes.
14. Service Providers and Operators
Elinkt may use third-party service providers to support the operation of the platform.
These may include providers responsible for services such as:
- Hosting
- Email delivery
- Infrastructure
- Security
- Database services
- Monitoring
- Backup
- Technical support
- Other infrastructure or services required to operate Elinkt
Where third parties process personal information on behalf of Elinkt, their role and contractual obligations should be appropriately documented.
15. Information Security
Elinkt takes reasonable and appropriate measures to protect personal information against risks by applying security measures where applicable; such as:
- Authentication controls
- Role-based access
- Password protection
- Email verification
- Access controls
- Encryption where appropriate
- Audit logging
- Secure development practices
- Monitoring
- Backup and recovery controls
No electronic system can guarantee absolute security.
16. Data Retention
Elinkt will retain personal information only for as long as reasonably necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.
Different information may therefore have different retention periods.
The final retention schedule should address, at minimum:
- Active profiles
- Deactivated profiles
- Live profiles awaiting deletion eligibility
- Deleted Demo profiles
- Deleted Live profiles
- QR Code records
- QR Code lifecycle/audit records
- Scan records
- Email verification records
- Administrative audit records
- Backups
- Security and incident records
17. Live and Demo Profiles
Elinkt may distinguish between Live and Demo profiles.
This distinction may affect how information and QR Codes are retained.
Live profiles
A Live profile may be deactivated and later reactivated.
Where a Live profile remains deactivated for the applicable period, it may become eligible for permanent deletion.
Following permanent deletion, the associated QR Code reference may be permanently retired and may not be returned to the available QR Code pool.
Demo profiles
Demo profiles may be deleted without the same waiting period.
Following deletion of a Demo profile, the associated QR Code reference may be released and returned to the available QR Code pool, subject to the applicable system controls.
Before a QR Code is reused, the previous association must be removed so that the previous profile information cannot be accessed through the QR Code.
Deletion of a profile does not necessarily mean that every technical or audit record can be immediately removed from every backup or security system.
18. Your Responsibilities
End Users are responsible for:
- Providing accurate information
- Keeping profile information up to date
- Protecting access to their email account
- Informing Elinkt if they believe their account has been compromised
- Reviewing information displayed through their Health Linkt profile
- Updating information when circumstances change
Because Health Linkt information may be used during an emergency, keeping information current is particularly important.
19. Cookies and Technical Information
The Elinkt website and services may use cookies or similar technologies where necessary for:
- Authentication
- Security
- Session management
- Service functionality
- Preferences
- Analytics or service improvement, where applicable
20. Changes to Personal Information
End Users can update information contained in their Health Linkt profile through the available profile-management functionality.
Where appropriate, Elinkt may require email verification before changes are accepted.
End Users should regularly review their profile to ensure that information remains accurate.
21. Privacy and Security Incidents
If Elinkt becomes aware of a security compromise involving personal information, the incident will be assessed and managed in accordance with applicable law and Elinkt’s security incident response procedures.
Where notification is legally required, affected data subjects and/or the Information Regulator will be notified in accordance with applicable requirements.
22. Changes to This Privacy Policy
Elinkt may update this Privacy Policy from time to time to reflect:
- Changes to the Elinkt service
- New functionality
- Changes to processing activities
- Changes to applicable law
- Changes to service providers
- Security or operational requirements
When material changes are made, appropriate notice will be provided where required.
23. Contact Us
If you have questions about this Privacy Policy, your personal information, or how your information is processed, please contact us:
Elinkt
Email: hello@elinkt.net