Prima Edge Health (Pty) Ltd ("PrimaEdge") provides health and wellness services through its digital platform and related services.
This Consent Notice explains the specific processing activities for which PrimaEdge asks a Member to make a separate consent choice. It should be read together with PrimaEdge's Privacy Notice, which explains more broadly how and why PrimaEdge processes personal information.
Health information is special personal information under the Protection of Personal Information Act 4 of 2013 ("POPIA") and is subject to additional protection, including applicable requirements governing the confidentiality and safeguarding of health information.
Not all processing undertaken by PrimaEdge depends upon consent. PrimaEdge may process personal information where another lawful ground recognised by POPIA or other applicable law permits or requires the processing. This Consent Notice applies specifically where PrimaEdge relies upon, or seeks, a Member's consent for the activities described below.
Each consent choice is presented separately and recorded independently. A Member may therefore grant or decline one consent without automatically granting or declining another.
PrimaEdge may ask for your consent to submit your individual health or screening information to your medical scheme for a specified purpose, including where relevant to a wellness programme or wellness-linked benefit.
PrimaEdge may ask for your consent for your information to contribute to aggregated and appropriately de-identified health and wellness reporting provided to a participating Employer.
This consent does not authorise your Employer to receive your individual health results. Employer reporting is designed to provide population-level health and wellness information without disclosing individual Member health results. PrimaEdge applies safeguards intended to reduce the risk that an individual Member can be identified from such reporting.
As an additional operational safeguard, PrimaEdge does not report a statistic representing fewer than 10 Members. The 10-Member threshold is an additional safeguard and is not, by itself, treated as establishing that information is anonymous.
PrimaEdge may ask for your consent for information derived from your health and wellness information to be used for research, statistical analysis, trend analysis and population-level health insights. This consent is optional.
Where reasonably practicable and appropriate to the research or statistical purpose, PrimaEdge will use information that has been de-identified and will apply safeguards designed to reduce the risk of individual Members being identified. Information processed under this consent will not be published in a form that identifies you as an individual.
Granting or declining research consent will not determine whether you may receive unrelated PrimaEdge health and wellness services. If you withdraw this consent, PrimaEdge will cease future research or statistical processing that depends upon your consent, subject to information already lawfully processed and any continued processing or retention permitted by applicable law.
The PrimaEdge app also asks for a separate, optional consent to send medication reminders and related messages on WhatsApp, using the phone number on your profile. Having a phone number on file does not by itself mean you have agreed to this, it is a distinct choice, and it is never required to use the service.
This purpose is not covered by the attorney-approved text in Section 2.1 to 2.3 above. The wording here reflects what the app actually does today and is included so the notice stays accurate, but it still needs the same legal review the other three purposes have already received before this notice can be treated as fully approved.
Your consent choices are voluntary, specific and informed. Where a particular optional service or functionality cannot be provided without the processing for which consent is requested, PrimaEdge will explain that consequence before you make the relevant choice.
PrimaEdge will not treat your acceptance of its Member/App Terms as consent to the separate activities described in this Notice.
Declining one consent does not automatically amount to declining another consent and will not prevent access to unrelated services.
PrimaEdge will not infer consent from silence, inactivity or acceptance of unrelated terms.
You may withdraw a consent previously given for a consent-dependent activity.
Withdrawal operates prospectively. It does not affect the lawfulness of processing undertaken before withdrawal and does not require PrimaEdge to destroy information that it is required or lawfully entitled to retain.
Where withdrawal relates to a disclosure or submission to a third party that has already lawfully occurred, withdrawal cannot reverse that previous disclosure. It will, however, apply to future disclosures or processing by PrimaEdge that depend upon the withdrawn consent.
The mechanism for withdrawing or changing consent will be made available through the app or another channel communicated by PrimaEdge.
PrimaEdge records each consent choice separately:
These records are maintained to provide an auditable history of the Member's consent choices and to support PrimaEdge's compliance obligations.
A material change to a consent-controlled purpose will not be implemented merely by changing the wording of this Notice. Where the nature or purpose of the consent materially changes, PrimaEdge will obtain an appropriate new consent where required.
This Consent Notice deals only with the specific consent choices described above. It does not contain the complete terms governing PrimaEdge's processing of personal information.
Further information about the categories and sources of personal information, purposes and lawful grounds for processing, Employer reporting, disclosures, retention, security, cross-border processing, data-subject rights and complaints is contained in PrimaEdge's Privacy Notice and, where applicable, its PAIA Manual and Data Governance Statement.
A Member who believes that personal information has been processed unlawfully may lodge a complaint with the Information Regulator of South Africa through its official channels, currently enquiries@inforegulator.org.za.
This Consent Notice should be read together with PrimaEdge's:
Those documents perform different functions and do not replace the specific consent choices recorded under this Notice.