Introduction
KAMLA respects your privacy and is committed to protecting Data. This Privacy Policy will inform you as to how we look after Data when you visit and use our Platform (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Glossary
You OR Your: shall refer to the users of our Platform.
Platform: It means KAMLA Platform whereby its Services shall be used.
Data: the information that we collect from users while using the Platform.
Services It means KAMLA services as described by the Terms and Conditions.
Account: It refers to the User account on the Platform.
KAMLA: It refers to the platform owned by Mermaid Technologies under commercial registration number 262634 Cairo Investment office, Tax Card No.769-419-895.
Service providers: refer to all independent third-party professionals, entities, or institutions engaged or connected through Kamla to provide services directly to users. These include, but are not limited to:
Licensed gynaecologists and fertility specialists who offer online consultations, medical advice, diagnosis, and follow-up services;
Psychiatrists and psychotherapists who provide mental health consultations and therapeutic support;
Certified nutritionists who offer dietary and lifestyle guidance;
Financial institutions and fintech partners that assess and provide financing solutions for fertility-related treatments such as IVF and egg freezing.
Laboratories, diagnostic centers, and wellness professionals, where applicable, that may offer complementary or follow-up services through the Platform.
Important information and who we are
Purpose of this Privacy Policy:
This Privacy Policy aims to give you information on how KAMLA collects and processes Data through your use of our Platform, including any Data you may provide through this Platform when you register and/or use our Services, as well as sign up to our Platform.
It is important that you read this Privacy Policy along with our Terms and Conditions when we are collecting or processing Data about you so that you are fully aware of how and why we are using this Data. This Privacy Policy supplements other notices and Privacy Policies and is not intended to override them.
Controller
MERMAID TECHNOLOGIES an LLC Company Commercial Registration No. 262634 Subject to the provisions of Law No. 72 of 2017 is the controller and responsible for Data (referred to as “KAMLA", "we", "us" or "our" in this Privacy Policy). MERMAID TECHNOLOGIES is the controller and responsible for this Platform.
Contact details
If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us through the email address:
E-mail address: Hello@kamla.health
Changes to the Privacy Policy and your duty to inform us of changes
We keep our Privacy Policy under regular review.
It is important that the Data we hold about you is accurate and current. Please keep us informed if Data changes during your relationship with us.
Third-party Links
This Platform may include links to third-party Platforms and plug-ins. Clicking on those links or enabling those connections may allow third parties to collect or share Data about you. We do not control these third-party Platforms and we are not responsible for their privacy statements. We recommend you read the Privacy Policy of every Platform you visit.
Children’s Privacy
Our Platform and Services are not intended for use by individuals under the age of 18. We do not knowingly collect personal data from individuals under this age. If we become aware that personal data has been collected from a child without verified parental or guardian consent, we will delete such data promptly.
Our services are not intended for children under the age of 18. Individuals under this age are not permitted to use the Platform or submit any personal data through our Services. We do not knowingly collect or process personal data from anyone under 18 years of age. If we become aware that we have inadvertently collected personal data from a child without verified parental consent, we will take immediate steps to delete such information.
Data that we collect
Data means any information about an individual or institution from which that entity can be identified. It does not include Data where the identity has been removed (anonymous Data).
We may collect, use, store and transfer different kinds of Data about you, which is including, but not limited to the following:
Identity Data includes first name, middle name, username, ID number or passport, date of birth and gender, Driver’s license, Club membership proof (if applicable),
Contact Data includes phone number, e-mail and postal addresses.
Medical data( from the Medical Form), which includes but is not limited to:
Medical history (e.g., chronic illnesses, surgeries, prior treatments)
Reproductive background (number of children, pregnancy attempts, miscarriages)
Lifestyle details (e.g. diet, smoking, physical activity)
Current medications or supplementsLab or test results submitted
Financial Data includes your bank account information, credit card details, cardholder name, expiration date, authentication code and billing address.
Technological Data includes your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and location, and other technology on the devices you use to access the Platform.
Profile Data includes your username and password, your interests, preferences, reviews and ratings, feedback, and survey responses.
Usage Data includes information about how you use our Platform and your transaction history.
Photos, reviews, social posts, and videos you may have provided to us.
Geolocation Data, in addition to the categories noted, we may also collect certain location Data if you have instructed your device to send such Data via the privacy settings on that device.
The incorporation documents for service providers from legal entities, which include but are not limited to (Articles of Association, Commercial Register, Tax Card, and investment gazette) are collected for the purpose of verifying and onboarding.
Sensitive Personal Data: we collect and process certain sensitive categories of personal data, such as health and financial information, to provide our services. These include medical history, reproductive background, lifestyle details, identity documents, and financial records. Such data is processed only when:
Necessary to provide medical consultations or facilitate financing;
The user gives explicit consent;
It is required by law.
We take additional safeguards when handling such sensitive data, including data minimization, encryption, and restricted access controls.
We also collect, use, and share aggregated Data such as statistical or demographic Data for any purpose. Aggregated Data could be derived from Data but is not considered Data in law as this Data will not directly or indirectly reveal your identity. For example, we may aggregate your usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect aggregated Data with Data so that it can directly or indirectly identify you, we treat the combined Data as Data which will be used under this Privacy Policy.
We do not collect any special categories of Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership). Nor do we collect any information about criminal convictions and offences.
At KAMLA, we use the data we collect to develop and train AI models to improve our services, including but not limited to: content personalization, improving the performance of our services. We emphasize that we are committed to protecting your privacy, we do not disclose sensitive information, and we ensure the security of your data through robust security technologies.
If you fail to provide Data
Where we need to collect Data by law, by using our Platform, and you fail to provide the required Data, we may not be able to perform our Services. We will notify you if this is the case at the time.
How is Data collected?
We use different methods to collect Data from and about you including through:
Direct interactions. You may provide us with identity, contact, medical, or financial data by:
Filling in the Medical History and Lifestyle Questionnaire on the platform to request an online consultation.Completing the Know Your Customer (KYC) Form when applying for fertility treatment financing.
Uploading medical or financial documents through your account.
Create an Account on and use our Platform;
Enter a social competition, promotion, or survey; or
Provide us with feedback or contact us.
Automated technologies or interactions. As you interact with our Platform, we will automatically collect technical data about your browsing actions and patterns. We collect this Data by using cookies, server logs and other similar technologies.
How we use Data
To the extent possible, we want to provide you with relevant content and a tailored experience when you use our Services, and we use Data about you to do that.
We will only use Data when the law allows us to. Most commonly, we will use Data in the following circumstances:
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
Where we need to comply with a legal obligation;
Where we need to set up your Account and administrate it;
Where we need to carry out surveys;
Where we need to personalize content, user experience or business information;
Where you have given consent.
Generally, we do not rely on consent as a legal basis for processing Data, although we will get your consent before sending third-party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use Data
1. Performance of our Services:
We process Data because it is necessary for the performance of our Services through our Platform.
In this respect, we use Data for the following:
To prepare a proposal for you regarding the Services we offer;
To provide you with the Services as set in the scope of our Services, or as otherwise agreed with you from time to time;
To deal with any complaints or feedback you may have;
For any other purpose for which you provide us with the Data which we collect
In this respect, we may share Data with or transfer it to the following:
Subject to your consent, independent third parties whom we engage with to assist in delivering the Services to you;
Our Professional Advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
Our Data storage providers.
The European General Data Protection Regulation (GDPR) and the Egyptian law no. 151 for the year 2020. Due to the said purposes, to guarantee security and a smooth connection setup, we have a legitimate interest in processing this Data.
2. Legitimate interests:
We also process Data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of a third party.
In this respect, we use Data for the administration and management of our business, marketing purposes, archiving or statistical analysis.
3. Legal Compliance:
We also process Data for our compliance with a legal obligation which we are under. In this respect, we will use Data for the following:
Resolve disputes or troubleshoot problems;
Prevent fraud and other potentially prohibited or unlawful activities;
Comply with relevant laws, respond to legal requests, prevent harm, and protect our rights and the rights of other users and third parties;
As required by tax authorities or any competent court or legal authority.
4. Marketing:
We will send you marketing about the Services we provide, which may be of interest to you, as well as other information in the form of alerts, newsletters, notifications for discounts and deals, or events which we believe might be of interest to you, or to update you with information which we believe may be relevant to you. We will communicate this to you in several ways, including by telephone, SMS, e-mail, or other digital channels as appropriate.
5. Communication:
Communicate with you or facilitate communication between you & our service providers;
Host your reviews, ratings, photos, videos, and other content;
Customize your experience, including customizing the ads shown to you on and off our Platform;
Respond to your questions and comments.
6. Promotional offers from us:
We may use Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which merchants, products, Services, discounts and deals may be relevant to you.
You will receive marketing communications from us in case of using our Platform, and you have not opted out of receiving these marketing communications.
7. Third-party marketing:
We will get your express opt-in consent before we share Data with any third party for marketing purposes or R&D.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you, or by contacting us at any time
8. Cookies:
You can adjust your browser settings to refuse all or some cookies, or to receive alerts when websites access them. Please note that restricting or blocking cookies may affect how this Platform functions. Certain features, such as registration, login, or secure browsing, may not work properly—or may be unavailable—if essential cookies are disabled. However, you may still be able to view and browse some content even if cookies are turned off.
9. Change of purpose:
We will only use the Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us on the e-mail address Hello@kamla.health. If we need to use the Data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so. Please note that we may process Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law
Explicit Consent for Medical and Financial Information
By completing the Medical History and Lifestyle Questionnaire or the KYC form on our Platform, you expressly consent to the collection, storage, and use of your sensitive personal data for:
Receiving fertility-related medical advice
Applying for financing services from third-party providers.
You may withdraw your consent at any time by contacting us. However, doing so may limit our ability to offer you certain services.
Disclosures of Data
We may share Data with the parties set out herein in relation to the specified purposes for which we will use the Data above.
To provide you with our services, Kamla shares certain personal data with:
Medical professionals who review your case and provide medical advice;
Licensed financial partners who assess your eligibility for fertility treatment financing.
We only share the minimum necessary data with these parties.
All third-party partners are bound by strict confidentiality and data protection agreements and may only use your information for the agreed purpose.
We may share Data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use Data in the same way as set out in this Privacy Policy.
Data security
We have put in place appropriate security measures to prevent Data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to Data to those employees, contractors, third-party service providers, and other parties who have a valid need to know. They will only process Data by our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your data may be stored or processed on servers located outside Egypt. We ensure that any such transfers comply with applicable laws and that adequate safeguards (e.g., contractual clauses, encryption, data minimization) are in place to protect your privacy.
Data retention
How long will we use Data?
We will only retain Data for as long as reasonably necessary to fulfil the purposes we collected it for, including to satisfy any legal, regulatory, or reporting requirements. We may retain Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with You.
To determine the appropriate retention period for Data, we consider the amount, nature, and sensitivity of the Data, the potential risk of harm from unauthorized use or disclosure of Data, the purposes for which we process Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, or other requirements
When it is no longer necessary to retain Data, we will delete it
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access Data (or to exercise any of your other rights). This is a security measure to ensure that Data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information to improve our Services.
How do we deal with the “right to be forgotten”?
You have the right to request the erasure of your data in certain circumstances — for example, if the data was not collected for a lawful purpose, or is no longer necessary for such purpose. This is commonly referred to as the 'right to be forgotten.' We will consider your request and, if the legal conditions are met, we will erase your data — particularly in cases where it is no longer necessary to retain it or it is no longer used for the purposes for which it was originally collected.
Lawful Basis
Legitimate Interest means our need to run and grow our business in a way that allows us to give you the best, safest, and most efficient service. Before using your data for our interests, we carefully check that this won’t unfairly harm your privacy. We never use your data in ways that go against your rights—unless you agree, or the law allows us to. If you’d like to know more about how we make these decisions, you can contact us at any time.
Complying with a legal obligation means processing Data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Professional advisers acting as processors or joint controllers including lawyers, bankers, and auditors, who provide consultancy, banking, legal and accounting services.
YOUR LEGAL RIGHTS
You have the right to:
Access to Data on our Platform. This enables you to receive a copy of the Data we hold about you and to check that we are lawfully processing it.
Request correction of the Data that we hold about you. This enables you to have any incomplete or inaccurate Data we hold about you corrected, though we may need to verify the accuracy of the new Data you provide to us.
Request erasure of personal Data. This enables you to ask us to delete or remove Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase Data to comply with local law.
You have the right to object to the processing of your data when we rely on a legitimate interest (or those of a third party), and there is something about your particular situation that makes you feel this processing affects your fundamental rights and freedoms. You also have the right to object to us processing your data for direct marketing purposes. If you object, we will stop sending regular marketing messages. However, we may still send occasional updates or limited offers related to our services if we believe they are relevant to you. You can unsubscribe from these at any time
Request restriction of the processing of Data. This enables you to ask us to suspend the processing of Data in the following scenarios:
If you want us to establish the Data's accuracy.
Where our use of the Data is unlawful, but you do not want us to erase it
Where you need us to hold the Data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of Data, but we need to verify whether we have overriding legitimate grounds to use it.
Withdraw consent at any time where we are relying on consent to process Data. However, this will not affect the lawfulness of any process carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Services to you. We will advise you if this is the case at the time you withdraw your consent.
You may revoke your consent for specific services at any time. For example, you may choose to: - Stop receiving marketing messages, but continue using our medical consultation service; - Withdraw from medical consultation but keep your financing application active.
You will not have to pay a fee to access Data (or to exercise any of the other rights).
How to contact us? If you have any questions about how we use Data, or you wish to exercise any of the rights set out above, please contact us at our contact details.
Third-Party Responsibility Disclaimer.
While Kamla facilitates access to medical and financing partners, all final decisions (such as diagnosis, treatment recommendation, or loan approval) are made by the respective third-party provider. Kamla is not responsible for the accuracy, outcome, or consequences of such decisions.
