INTRODUCTION

At Vikand Medical Solutions, LLC (“VIKAND”), we are dedicated to upholding our responsibilities under a multitude of national data protection laws, recognizing the diverse backgrounds of guests who come from various nations. These laws encompass, but are not limited to, the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the European Union's General Data Protection Regulation ("GDPR"), and any other applicable national data protection legislation.

Recognizing the global scope of our operations and the diverse origins of our cruise clients’ guests, we are steadfast in our commitment to compliance with data protection laws from around the world. While GDPR governs the use of and apply to all personal data of individuals falling within their respective scopes, HIPAA has a narrower focus and exclusively pertains to HIPAA-protected health information. Given the importance of data security and to address potential overlaps, this Privacy Policy incorporates more stringent provisions to supplement and resolve any ambiguities that may arise.

PURPOSE

VIKAND's primary purpose of processing any sensitive personal data and protected health information is to conduct a thorough review of guests' Medical Screening Forms, ensuring the well-being and safety of guests on board its cruise clients' vessels. Specifically, the processing of this sensitive personal data and protected health information contained in these forms is to conduct a comprehensive assessment of these guests to ensure they are fit for travel onboard VIKAND’s cruise clients’ vessels.

VIKAND is committed to protecting sensitive personal data and protected health information included in these Medical Screening Forms, in accordance with any applicable data protection laws and ensures the data is used only for the above stated purpose.  VIKAND is committed to providing its clients with a medical record review method that is safe, secure and trustworthy. For a current list of cruise line clients, see www.vikand.com.

CONSENT

VIKAND assures that each guest grants them proper explicit, affirmative, unconditional, and unambiguous consent and authorization through clear affirmative action prior to processing any sensitive personal data or protected health information.  The guest further authorizes VIKAND to administer and store this data for the purpose outlined above.

By selecting an online appointment with a VIKAND Doctor, guests agree that, if necessary, the VIKAND Doctor may complete the Guest Section of the Medical Screening Form on their behalf, based on their verbal responses gathered during the consultation. Guests have the option to indicate their agreement or disagreement with this practice. Consent is voluntary, and guests may choose to complete the form themselves.

Further, for parents or legal guardians accompanying children, they are permitted to complete the questionnaire on behalf of their child. However, they must confirm their role as the holder of parental responsibility and demonstrate the capacity to provide consent on their child's behalf.

For individuals with limited mental capacity, as determined by a court, and with an appointed guardian, it is necessary to ensure that the guardian completes the questionnaire on their behalf. This process includes confirming their role as the guardian and providing consent on behalf of the individual with limited mental capacity.

PERSONAL DATA RECEIVED

VIKAND provides a service whereby it conducts a medical review of guests sailing on its clients’ vessels.  When contracted to do so, VIKAND receives Medical Screening Forms for review from the cruise line or its guests. These forms contain sensitive personal data and protected health information provided by the guests. In the course of providing this service, VIKAND will collect and process this sensitive personal data and protected health information. This processing is essential for creating a comprehensive medical profile of guests, determining their fitness to travel on board VIKAND’s clients' cruises.

USE OF DATA RECEIVED

The data received are used for the sole objective of reviewing Medical Screening Forms prior to boarding one of VIKAND’s clients’ vessels. This process is vital to ensure the health and safety of guests during their cruise. Any external communication regarding this sensitive personal data or protected health information is limited to the cruise line with whom the guest will embark.  VIKAND does not share this information with any other outside parties.  We inform our clients that any sensitive personal data or protected health information received from VIKAND can only be used for purposes for which it was intended, as outlined above.

STORAGE OF PERSONAL DATA

Medical Screening Forms are stored in accordance with HIPAA, EU data protection laws, and any other applicable data protection legislation.  This data is retained in accordance with flag state requirements, and upon the expiration of the mandated retention period, personal data will be promptly and securely deleted. VIKAND is committed to safeguarding the confidentiality, integrity, and availability of this personal data in accordance with the applicable data protection laws.

CHANGE OR REMOVE DATA

At any time, the cruise line or any guest whose medical information has been reviewed by VIKAND upon request from one of its clients, is entitled to contact VIKAND to access their personal data, to make changes, or to request that some or all of the personal data be removed from our system. This can be done by writing to info@vikand.com.  Requests received in writing will receive a response within 30 days of receipt of request.

DATA PROTECTION POLICIES

In regards to its personal data policy, VIKAND is subjected to the laws of the United States Federal Trade Commission and when requested by legal authorities of the United States may be obligated to provide access to any personal data received if requested for legal or security reasons.

Additionally, VIKAND is fully committed to achieving full compliance with the General Data Protection Regulations (GDPR) and will conform to all principles associated with data protection policies in all European countries, as well as any other applicable data protection legislation.

If you have any questions or require further information about VIKAND’s data protection practices, please feel free to contact VIKAND’s Data Protection Officer, Daniel Gonzalez, at daniel.gonzalez@vikand.com. VIKAND are committed to maintaining transparency and addressing any inquiries any client or guest may have regarding the protection and privacy of their data.