Privacy Policy
Your privacy is important to us. Learn how we collect, use, and protect your personal information.
Last Updated: December 1, 2025
1. Introduction
Welcome to OnLocum. This Privacy Policy explains how OnLocum ("we," "us," or "our") collects, uses, discloses, and protects your personal information when you use our platform, mobile applications, and services.
OnLocum operates a healthcare workforce management platform providing locum staffing, home-based care coordination, medical transport coordination, and medical logistics services across Kenya and Africa.
By using OnLocum, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with this policy, please do not use our services.
2. Information We Collect
2.1 Information You Provide
- Account Information: Name, email address, phone number, date of birth, gender, profile photo
- Identity Verification: Government-issued ID, professional certifications, and medical licenses
- Payment Information: Credit/debit card details, mobile money wallet information, bank account details
- Professional Information: CV/resume, education history, work experience, skills, certifications (for healthcare professionals and service providers)
- Facility Information: Business name, registration number, address, department information (for healthcare facilities)
2.2 Information We Collect Automatically
- Location Data: GPS coordinates, IP address, device location (for shift check-ins, medical operations, and emergency coordination)
- Device Information: Device type, operating system, unique device identifiers, mobile network information
- Usage Data: App interactions, features used, search queries, booking history, and shift history
- Communication Data: In-app messages, customer support interactions, push notification preferences
2.3 Information from Third Parties
- Social media profiles (Facebook, Google, Apple Sign-In)
- Payment gateway providers (Flutterwave, M-Pesa)
- Background check providers (for professional verification)
- Maps and location services (Google Maps, Huawei Maps)
3. How We Use Your Information
We use your information for the following purposes:
3.1 Service Delivery
- Processing bookings, shift requests, and service requests
- Matching healthcare facilities with qualified professionals
- Facilitating home-based care, emergency dispatch, and medical logistics coordination
- Real-time location tracking during service delivery and shift check-ins
- Payment processing and invoicing
3.2 Safety and Security
- Identity verification and background checks
- Fraud prevention and detection
- Emergency response coordination (ambulance dispatch)
- Incident investigation and dispute resolution
3.3 Communication
- Service updates and notifications
- Customer support and assistance
- Marketing communications (with your consent)
- Important policy updates
3.4 Platform Improvement
- Analytics and usage patterns
- Feature development and optimization
- A/B testing and performance monitoring
4. Data Sharing and Disclosure
We share your information with third parties only as described below:
4.1 Service Matching
- Healthcare facilities see limited professional information (name, photo, credentials)
- Professionals see facility information for shift opportunities
- Assigned transport/logistics providers may see pickup, drop-off, and contact details needed to fulfill a request
4.2 Third-Party Service Providers
- Google Cloud Platform: Cloud storage, infrastructure, APIs
- Firebase: Push notifications, analytics, crash reporting
- Twilio: SMS notifications, voice calls, video calls
- Flutterwave & M-Pesa: Payment processing
- PubNub: Real-time messaging
- Memcached: Performance optimization
- Google Maps & Huawei Maps: Location services
4.3 Legal Requirements
We may disclose your information if required by law, court order, or government regulation, or to protect the rights, property, or safety of OnLocum, our users, or the public.
4.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.
5. Data Security
We implement industry-standard security measures to protect your information:
- Encryption: TLS/SSL encryption for data transmission, AES-256 encryption for stored data
- Access Controls: Role-based access, multi-factor authentication for admins
- Secure Infrastructure: Google Cloud Platform with security best practices
- Regular Audits: Security vulnerability scanning and penetration testing
- Incident Response: Breach notification procedures in compliance with regulations
However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your information.
6. Data Retention
We retain your information for the following periods:
- Active Accounts: Throughout account lifetime and 1 year after deletion (for legal compliance)
- Trip/Shift History: 5 years (for tax and legal requirements)
- Payment Records: 7 years (for financial auditing)
- Communication Logs: 2 years
- Location Data: 30 days (unless part of incident investigation)
You may request deletion of your data at any time (see Section 7).
7. Your Rights (GDPR Compliance)
Under GDPR and Kenya Data Protection Act 2019, you have the right to:
7.1 Access
Request a copy of your personal information we hold (data portability).
7.2 Correction
Update or correct inaccurate information in your account settings.
7.3 Deletion
Request deletion of your account and associated data (subject to legal retention requirements).
7.4 Objection
Object to processing of your data for direct marketing purposes.
7.5 Restriction
Request restriction of processing under certain circumstances.
7.6 Withdrawal of Consent
Withdraw consent for processing (e.g., marketing communications, location tracking).
To exercise these rights, contact us at privacy@onlocum.com.
9. Third-Party Services
OnLocum integrates with third-party services. We are not responsible for their privacy practices. Please review their policies:
10. Children's Privacy
OnLocum is not intended for users under 18 years of age. We do not knowingly collect information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@onlocum.com.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes via:
- Email notification
- In-app notification
- Prominent notice on our website
Continued use of OnLocum after changes constitute acceptance of the updated policy.
12. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us:
OnLocum Data Protection Officer
Email: privacy@onlocum.com
General Inquiries: support@onlocum.com
Address: Nairobi, Kenya
Phone: +254 XXX XXX XXXX