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PRIVACY POLICY

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CARIBVITALS HEALTH LTD.

Connecting Care. Empowering Health.

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Privacy Policy

Effective 11 September 2026  |  Version 1.0

 

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Privacy at a glance

• CaribVitals handles health-related information because it is necessary to provide a non-clinical wellness continuity service.

• We do not sell personal information or health information.

• We do not use health information for third-party advertising.

• Caregiver/family-member report sharing occurs only when the Client has authorized that named recipient and the applicable caregiver entitlement is active.

• You may ask us to access or correct information we hold about you and may withdraw optional sharing permissions prospectively.

• We use service providers for hosting, forms, communications, payment processing and other business operations. Some providers may process data outside Trinidad and Tobago.

 

Contents

1. About This Privacy Policy

2. Who We Are and How to Contact Us

3. Scope of This Policy

4. Personal Information We Collect

5. Health and Other Sensitive Information

6. Caregiver / Family Member Information

7. How We Collect Information

8. Why We Use Personal Information

9. Consent, Authorization and Service Necessity

10. How We Share Information

11. Caregiver Report-Copy Sharing

12. Service Providers and International Processing

13. Payments and Financial Information

14. Document Storage and Uploaded Records

15. MyCaribVitals, Website Use and Cookies

16. Email, WhatsApp and Other Communications

17. Accuracy, Corrections and Identity Matching

18. Information Security

19. Retention and Deletion

20. Your Privacy Choices and Requests

21. Revoking Caregiver Authorization

22. Suspension, Cancellation and Historical Records

23. Privacy or Security Incidents

24. Information About Minors

25. Changes to This Policy

26. Questions, Complaints and Contact

1. About This Privacy Policy

This Privacy Policy explains how CaribVitals Health Ltd. ("CaribVitals", "we", "us" or "our") collects, uses, stores, discloses, protects, retains and otherwise handles personal information when a person uses our services, website, forms, MyCaribVitals portal, communications, reports or optional add-ons.

CaribVitals is a non-clinical wellness continuity service. Because the service helps organize and preserve health-related information between healthcare visits, some of the information we handle is sensitive personal information.

This Policy is intended to align with the General Privacy Principles under the Data Protection Act, Chap. 22:04 of the Laws of Trinidad and Tobago, and with other applicable legal requirements. It should be read together with the CaribVitals Terms of Service and any service-specific consent or authorization presented to you.

2. Who We Are and How to Contact Us

CaribVitals Health Ltd. is the organization responsible for the personal information it controls in connection with the CaribVitals service.

• Telephone / WhatsApp: (868) 799-2020

• Email: info@caribvitalshealthltd.com

• Privacy requests: use the email above and place “Privacy” in the subject line.

We may introduce a dedicated privacy email address in the future. If we do, the current address will be published on our website and in the current version of this Policy.

3. Scope of This Policy

This Policy applies to information handled through CaribVitals core service, onboarding, check-ins, appointment updates, health updates, uploaded documents, Wellness Continuity Reports, MyCaribVitals, caregiver/family-member report-copy delivery, Document Storage, customer support, payment administration, website interactions and related service operations.

It does not govern the independent privacy practices of doctors, hospitals, laboratories, pharmacies, payment processors, website platforms, communications providers or other third parties that operate under their own privacy policies.

4. Personal Information We Collect

Depending on the service used, we may collect or maintain information such as:

• identity information, including name, date of birth, age, gender and CaribVitals client identifier;

• contact information, including telephone number, WhatsApp number, email address, street address, city/town, region and country;

• service information, including plan selected, activation date, service status, batch assignment, add-on selections and renewal status;

• payment administration information, including payment method, payment status, transaction/reference information, invoice or receipt details, coverage dates and amounts;

• caregiver/family-member information, including name, relationship, contact details, authorization status, caregiver record identifier, paid coverage and report-delivery history;

• communications and service-support records, including emails, messages, follow-up notes, requests, complaints and operational actions;

• portal, website and technical information, such as account activity, device/browser information, security logs and cookie or analytics information where used; and

• audit and operational records used to document consent, corrections, exceptions, manual recovery, report delivery and other service actions.

5. Health and Other Sensitive Information

CaribVitals may collect and organize health-related information supplied by you or an authorized source. This may include:

• medical conditions, diagnosis history and year diagnosed;

• medications, supplements, dosage, frequency, adherence information and reported side effects;

• allergies and sensitivities;

• symptoms, wellness check-in information and reported changes;

• appointments, doctors, specialists and places of care;

• procedures, surgeries, scans, imaging and related records;

• vital-sign or wellness measurements that you submit;

• healthcare-related documents, laboratory reports, imaging reports or other records you choose to provide; and

• information contained in CaribVitals continuity reports and related notes.

Health and medical-condition information is sensitive personal information. We use it only for service delivery, continuity, authorized sharing, support, security, legal/compliance needs and other purposes described in this Policy. We do not sell health information and do not provide it to third parties for their independent advertising.

6. Caregiver / Family Member Information

If a Client selects or later adds a Caregiver/Family Member Add-On, CaribVitals may collect the proposed caregiver’s name, relationship to the Client, phone/WhatsApp details, email address and other information needed to establish the caregiver record and deliver an authorized report copy.

The Client’s authorization is required before CaribVitals sends health-related report information to a caregiver/family-member recipient. A caregiver may also provide or confirm their own contact and payment information where necessary.

Caregiver records are preserved historically. Replacing one caregiver with another does not overwrite the former caregiver’s record. Each recipient is tracked separately so CaribVitals can determine who was authorized and eligible to receive a report copy for a particular period.

7. How We Collect Information

We may collect information:

• directly from the Client through consultation, onboarding, check-ins, forms, portal actions, telephone, email, WhatsApp and other approved communications;

• from an authorized caregiver, family member, representative or other person acting with appropriate authority;

• from documents or records submitted to CaribVitals by the Client or an authorized source;

• from payment processors or transaction evidence used to verify payment status;

• automatically through our website, portal or technical systems where cookies, logs or security functions are used; and

• from our own operational activity, including report generation, delivery, payment tracking, service status, exceptions and audit records.

8. Why We Use Personal Information

We use personal information only for purposes that are reasonably connected with operating CaribVitals and providing the service requested. These purposes include:

• creating and maintaining the Client’s CaribVitals record and permanent CLIENT_ID;

• verifying identity, contact information, authority and caregiver authorization;

• providing core continuity services and optional add-ons;

• organizing health and wellness information and preparing eligible CaribVitals reports;

• delivering Client reports and, where separately authorized and paid, caregiver/family-member report copies;

• processing and verifying payments, invoices, receipts, coverage and renewal status;

• providing reminders, follow-up, customer support and operational communications;

• operating MyCaribVitals and related forms, storage and submission functions;

• investigating mismatches, failed delivery, disputes, security events, duplicate records or other exceptions;

• maintaining audit, continuity, quality, security, accounting and compliance records;

• improving our service, processes and system reliability using information appropriately limited for that purpose; and

• meeting legal obligations, responding to lawful requests and protecting the rights, safety and security of Clients, CaribVitals and others.

9. Consent, Authorization and Service Necessity

Some information is necessary for CaribVitals to provide the core service. If required information is not provided, we may be unable to activate or continue a particular service function.

Other processing depends on a specific choice or authorization. For example, sharing a Client report with a caregiver/family member requires Client authorization, and optional Document Storage requires the Client to select and activate that add-on.

Where CaribVitals asks for consent or authorization, it should be informed and connected to a stated purpose. You may withdraw optional consent or authorization prospectively, subject to reasonable identity verification and any information we must retain for legitimate business, audit or legal reasons.

10. How We Share Information

CaribVitals does not sell personal information or health information. We may disclose information only where reasonably necessary for the service or where otherwise permitted or required, including:

• to the Client who is the subject of the information;

• to an authorized caregiver/family-member recipient for the specific report-copy entitlement approved by the Client;

• to service providers that support hosting, forms, storage, email, communications, website/portal functions, payment processing, document processing, security or other business operations;

• to professional advisers such as legal, accounting, security or compliance advisers where reasonably necessary and subject to appropriate confidentiality expectations;

• to a regulator, court, law-enforcement body or other authority where disclosure is lawfully required or permitted; or

• in connection with a legitimate corporate transaction, restructuring or transfer, subject to appropriate confidentiality and privacy protections.

CaribVitals does not disclose Client health information to a doctor, hospital, insurer, employer, family member or other person merely because they ask. A lawful basis, Client authorization or other appropriate authority must exist.

11. Caregiver Report-Copy Sharing

The Caregiver/Family Member Add-On is a recipient-specific report-copy entitlement. When all applicable conditions are met, CaribVitals may send the named caregiver/family member a copy of the same eligible final report delivered to the Client.

Before caregiver delivery, CaribVitals should confirm that the Client’s core service is active, the caregiver record is current, the Client’s authorization remains valid, the specific caregiver entitlement is paid/eligible for the relevant period, and a valid delivery address is available.

If the Client revokes authorization or replaces the caregiver, future report delivery to the former caregiver stops from the effective change date. Revocation cannot recall or erase a report that was already lawfully delivered before the revocation took effect.

12. Service Providers and International Processing

CaribVitals uses third-party technology and business providers to operate efficiently. Current or future providers may support services such as Google Workspace/Drive/Forms/Sheets, website and portal hosting, payment processing, email, messaging, document generation, analytics, security and related functions.

Some service providers may store or process information outside Trinidad and Tobago. Where information is processed internationally, CaribVitals seeks to use reputable providers and reasonable contractual, technical and organizational safeguards appropriate to the information and service involved.

Third-party providers may also process some information under their own terms and privacy policies. CaribVitals does not control a third party’s independent processing outside the services it provides to CaribVitals.

13. Payments and Financial Information

CaribVitals records payment administration information needed to determine whether a core service or add-on is paid, pending, refunded, reversed, overdue or otherwise subject to review.

Where a payment processor is used, payment card or banking information may be collected directly by that provider rather than by CaribVitals. CaribVitals generally relies on transaction status, references and other verification information necessary to administer the service.

Core payments and add-on payments are tracked as separate entitlements. Caregiver payment coverage is recipient-specific and should be linked to the applicable caregiver record and coverage period.

14. Document Storage and Uploaded Records

Clients may submit documents needed for the core CaribVitals service and may separately purchase the optional Document Storage Add-On. Information in uploaded documents may include sensitive health information.

Loss or suspension of the optional Document Storage Add-On does not prevent CaribVitals from retaining or receiving records reasonably needed to provide the core service, maintain continuity, resolve an issue, preserve an audit trail or meet legal requirements.

Where the Document Storage Add-On is suspended, portal access to stored documents may later become restricted in accordance with the current service rules. We do not automatically delete records solely because an add-on payment lapses. Retention is governed by Section 19 of this Policy and CaribVitals’ records procedures.

15. MyCaribVitals, Website Use and Cookies

MyCaribVitals and the CaribVitals website may collect technical information needed to operate, secure and improve the online experience. This can include IP address, browser/device information, login or session information, page interactions, security events and cookies or similar technologies.

We may use essential cookies for security, sign-in and basic site functions. Where analytics, preference or other non-essential cookies are used, we aim to provide appropriate notice or controls through the website platform.

Website visitors should review any cookie banner or cookie settings made available on the CaribVitals website. Disabling certain cookies may affect some site or portal functions.

16. Email, WhatsApp and Other Communications

CaribVitals may communicate through email, telephone, WhatsApp, portal notifications or other channels you provide or agree to use. These channels have different privacy and security characteristics.

You are responsible for providing current contact information and for considering who may have access to your email account, telephone, device or messaging application. If you believe a communication channel is no longer secure, tell CaribVitals so we can update the approved contact method where reasonably possible.

CaribVitals will not intentionally include more sensitive information in a routine reminder or service-status message than is reasonably necessary for its purpose.

17. Accuracy, Corrections and Identity Matching

CaribVitals relies on accurate information to preserve continuity. We may ask you to confirm or correct information if names, dates, contact details, caregiver information, payments or other material data do not match.

A data mismatch should be corrected through the appropriate controlled process rather than by creating a duplicate Client record. Where a correction changes an authoritative identity or sensitive field, CaribVitals may require additional verification or managerial approval.

You should notify us if you believe material information in your CaribVitals record or report is inaccurate or incomplete.

18. Information Security

CaribVitals uses reasonable administrative, technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, misuse or destruction.

Measures may include role-based access, account permissions, controlled source records, audit logging, password and account protections, access restrictions, backup/recovery practices, secure provider configurations, exception handling and staff procedures.

No internet, email, cloud, device or information system can be guaranteed completely secure. If you become aware of unauthorized access, a lost device, compromised credentials or suspicious activity involving CaribVitals information, contact us promptly.

19. Retention and Deletion

CaribVitals retains personal information for as long as reasonably necessary for the purposes for which it was collected, including active service delivery, continuity, payment/accounting administration, audit history, dispute handling, privacy/security review, legal obligations and legitimate business records.

Retention periods may differ by record type. Client identity, report, caregiver, consent, payment, document and audit records may need to be kept after a service or add-on ends so that CaribVitals can preserve an accurate history and respond to later questions, disputes or legal requirements.

CaribVitals does not automatically erase a Client’s permanent identity, prior reports, caregiver history, document history or audit history merely because service is suspended, inactive, cancelled or not renewed.

When information is no longer reasonably required and there is no legal, contractual, security, audit or dispute reason to retain it, CaribVitals may securely delete, anonymize or otherwise dispose of it in accordance with its records procedures.

A more detailed records-retention schedule may be published or adopted as CaribVitals’ operations mature. This Policy does not promise immediate deletion where retention is reasonably necessary.

20. Your Privacy Choices and Requests

Subject to reasonable identity verification and applicable legal or operational limitations, you may contact CaribVitals to:

• ask what personal information CaribVitals holds about you;

• request correction of information that is inaccurate or incomplete;

• update your contact details or communication preferences;

• withdraw optional consent or caregiver-sharing authorization prospectively;

• ask questions about how your information is used or disclosed;

• request deletion of information that is no longer required, recognizing that some records may need to be retained for legitimate business, audit, security, contractual or legal reasons; or

• raise a privacy complaint or concern.

Where applicable law gives you additional rights, CaribVitals will handle requests in accordance with those requirements. We may need to keep a record that a request was made and how it was resolved.

21. Revoking Caregiver Authorization

The Client may revoke or change caregiver/family-member authorization at any time prospectively. CaribVitals may require reasonable verification before changing an authorization that controls access to health-related information.

When authorization ends, future caregiver report-copy delivery to that person stops. The former caregiver’s historical record and prior lawful delivery history remain preserved for audit and continuity purposes.

A new or replacement caregiver is treated as a separate recipient. The new caregiver must have valid Client authorization and their own paid entitlement before receiving future report copies.

22. Suspension, Cancellation and Historical Records

Suspending or ending service does not automatically delete information. CaribVitals preserves historical records that are reasonably necessary to maintain continuity, payment history, report history, caregiver history, consent history, security records and auditability.

If a Client later reactivates, CaribVitals normally continues the same Client identity rather than creating a new one. Information may be reviewed or updated where necessary before service resumes.

23. Privacy or Security Incidents

If CaribVitals becomes aware of a privacy or security incident affecting personal information, we will assess the nature and scope of the incident, take reasonable steps to contain and investigate it, and document appropriate corrective actions.

Where notification to affected persons, service providers, regulators or other authorities is required by applicable law or is otherwise appropriate based on the risk, CaribVitals will provide notice through a reasonable channel.

24. Information About Minors

CaribVitals services are primarily designed for adult Clients. We do not knowingly establish a minor as an independent Client without appropriate involvement and authorization from a parent, guardian or other lawful representative.

If services are offered for a minor in a particular case, CaribVitals may require additional verification of authority, consent and contact arrangements before collecting or sharing sensitive information.

25. Changes to This Policy

CaribVitals may update this Privacy Policy as the service, technology, providers, legal requirements or operating model changes. The current version will be identified by an effective date and version number.

Material changes that significantly affect how personal information is collected, used or disclosed will be communicated through a reasonable channel, such as the website, MyCaribVitals, email or another approved communication method.

Where a material change requires renewed consent or authorization for a particular activity, CaribVitals will seek that consent before relying on the new use where reasonably required.

26. Questions, Complaints and Contact

For privacy questions, access/correction requests, caregiver-authorization changes or complaints, contact:

CaribVitals Health Ltd.

Email: info@caribvitalshealthltd.com

Telephone / WhatsApp: (868) 799-2020

Subject line for privacy matters: Privacy

We may ask for reasonable information to verify your identity or authority before disclosing, correcting or changing sensitive information. If a concern cannot be resolved directly with CaribVitals, you may also seek any complaint or redress mechanism available under applicable Trinidad and Tobago law.

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