This Privacy Policy for GreenNotes (Pty) Ltd ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at help@greennotes.co.za.
This summary provides key points from our Privacy Policy. You can find out more details about any of these topics in the sections below.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any special personal information? We may process special personal information when necessary with your consent or as otherwise permitted by applicable law.
Do we collect any information from third parties? We collect information from a third party only where you connect one yourself — specifically, if you sign in with Google or connect your Google Calendar, we receive the data described in section 2.
Do we handle Google user data? Yes, if you choose to sign in with Google or to connect your Google Calendar. We access only your basic Google profile and, from your calendar, the times you are busy. GreenNotes writes its appointments into a separate calendar it creates, never into your existing one. We never use this data for advertising or to train AI models, and we delete it when you disconnect. Section 2 sets this out in full.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
In what situations and with which types of parties do we share personal information? We share information with the service providers that help us run the Services. Those that process practice and patient information are listed on our Sub-processors page.
Do we transfer personal information outside South Africa? Our system of record is in South Africa. Some features, in particular AI-assisted transcription and documentation, involve processing in the European Union and the United States under data processing agreements. Section 4 explains this.
How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Under POPIA, GreenNotes has two roles, depending on the information:
| Information | GreenNotes’ role |
|---|---|
| Patient records a practice keeps in GreenNotes, including consultations, notes, documents and attachments | Operator, for the practice |
| Consultation recordings and transcripts processed for a practice | Operator, for the practice |
| Patient invoices, payments and medical-aid claims a practice creates | Operator, for the practice |
| Clinician and staff account and profile information | Responsible party |
| Subscription and payment information for a practice’s GreenNotes account | Responsible party |
| Website enquiries, demo and webinar registrations, and marketing | Responsible party |
| Website analytics and cookie data | Responsible party |
| How you found GreenNotes, kept with your account when you sign up, or with your enquiry when you book a demo, register for a webinar or contact us | Responsible party |
Where we are the operator, the practice is the responsible party: it decides why and how the information is processed, and our Data Processing Agreement governs what we do with it. Where we are the responsible party, this Privacy Policy describes our processing.
In doing so, we commit to the following:
Our Data Processing Agreement sets out these commitments in full and forms part of our Terms and Conditions.
You warrant that you are the responsible party in respect of all personal information relating to data subjects that you upload, submit, or otherwise make available through our Services, and that you have obtained all necessary consents, authorisations, and legal bases required under applicable data protection laws.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
If you use our Services to process the personal information of your data subjects, such information may include special personal information, in particular health information. Consultation recordings are used only to produce transcripts and clinical notes; GreenNotes does not use voice recordings or any other biometric information to identify anyone. The optional biometric lock in our mobile app is handled entirely by your device, and GreenNotes never receives your biometric data. We process special personal information only on behalf of the practice that holds it, or where otherwise permitted by applicable law.
Card payments are processed by our payment provider, Paystack, in its own secure checkout. We never receive or store your full card number or its security code. We keep only a payment token, the card brand and its last four digits, so that we can charge your subscription and show you which card is on file. If you pay by EFT, we keep the payment reference and amount so that we can match the payment to your account.
If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
We automatically collect certain information when you visit, use, or navigate the Services. Some of this information is linked to your account: for example, the devices you use GreenNotes on, and the IP address, browser and app version of your requests. We use it to keep your account secure (for example, to recognise your devices and to block a lost or stolen device) and to troubleshoot problems. The information may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, approximate location derived from your IP address, information about how and when you use our Services, and other technical information.
Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:
When a visit to greennotes.co.za or app.greennotes.co.za begins, we note how you arrived. The web portal does this only on its home, sign-in, sign-up and subscription pages, never on a clinical page. We note:
utm_source and utm_campaign;gclid, fbclid and msclkid) and, only if you have accepted cookies, Meta’s browser identifier (the _fbp cookie);A visit ends after 30 minutes without activity, and reloading a page does not start a new one. We also give your browser a random identifier, and each visit one of its own, so that your visits can be linked together. Neither contains your name, your email address or anything else about you. We keep the first visit we noted and up to ten of the most recent ones. When you follow a link from our website to the web portal, the link carries this record to the portal, together with the name of the link you used (for example, the “Start free trial” button on our home page). The portal removes it from the address bar as soon as it has read it.
Until you create an account or send us one of our forms, we do not store this record: it stays in your browser. Section 5 explains where your browser keeps it, and for how long.
When you create an account, the web portal sends the record with your sign-up, and we keep it with your account, and with your practice if you created one. We add how you signed up (for example, as a new practice or by invitation), whether you had accepted cookies, whether you used a computer, phone or tablet (worked out from your browser’s user agent), and the channel your visits point to (for example, “Paid Search” or “Organic Social”). We keep the advertising click identifiers separately, in records that only our own systems can read.
When you book a demo, register for a webinar or send us an enquiry, the form sends the record with your submission, and we keep it with your enquiry, together with the kind of enquiry and, for a demo, your preferred day and time. We do not keep the advertising click identifiers with an enquiry. The details you typed into the form (your name, email address and phone number and, where you gave them, your practice’s name and your speciality) we keep separately, for our sales team to follow up. The message or notes you write in the form are not part of this record. With the enquiry we also keep a one-way code made from your email address (a keyed hash, not the address itself), so that if you later create a GreenNotes account with the same email address, once you have verified it, we can link your enquiry to your account.
Why, and on what basis. We use this record only for our own reporting: to understand which of our channels and campaigns bring practices and enquiries to GreenNotes, and so where to spend our marketing effort. We rely on our legitimate interest in doing so (section 11(1)(f) of POPIA), which is why we keep the record whether or not you accept cookies. It is not shown in GreenNotes, we do not use it to profile you, and it never affects your price, your trial or what you can do in GreenNotes. We do not sell it, and we do not send it to Meta, Google or any other advertising platform; the advertising measurement described in section 5 is separate from it.
How long. We delete the advertising click identifiers 395 days (about 13 months) after the visit they came from. We delete the details you typed into a demo, webinar or contact form 24 months after you sent it. The rest of the record stays with your account and your practice until they are deleted, and the part kept with an enquiry stays with the enquiry until we delete the enquiry. You can object to this record at any time (see section 10).
If you sign in with Google or connect your Google Calendar, we also process a limited set of data from your Google Account. Because Google user data carries specific obligations, we describe it separately and in full in section 2, “How Do We Handle Google User Data?” below.
GreenNotes offers two optional integrations with Google: Sign in with Google and Google Calendar sync. Neither is required in order to use GreenNotes. You can register with an email address and password instead, and the calendar built into GreenNotes works whether or not you connect an external calendar.
This section sets out specifically what Google user data GreenNotes accesses, why we need it, how we store and protect it, who we share it with, and how you can withdraw access and have it deleted. It applies in addition to the rest of this Privacy Policy. Where any other part of this policy conflicts with this section, this section governs our handling of Google user data.
We request the narrowest set of permissions (“scopes”) that will operate the features described below. Google displays these scopes to you on its own consent screen before any access is granted, and you decide whether to allow them.
For readability the scopes below are shown without their https://www.googleapis.com/auth/ prefix.
| Google permission we request | Google user data we receive | Why we need it | Where you see it in GreenNotes |
|---|---|---|---|
openid and userinfo.email | Your Google Account identifier and the email address on that account, and whether Google has verified it | To create your GreenNotes account, to recognise you as the same user each time you return, and to send you service messages such as password, billing and security notices | The Continue with Google button on the sign-up and sign-in screens at app.greennotes.co.za and in the iOS and Android apps |
userinfo.profile | Your name, and your profile picture and locale if your Google Account has them set | To show your name and picture in your GreenNotes profile and to your practice team, and to pre-fill your details at sign-up so you do not have to retype them | Your profile page, and the team member list in your practice settings |
calendar.app.created | No data from your existing calendars. This permission is limited to a separate calendar named GreenNotes that the app creates in your Google Account, and to the appointments GreenNotes itself writes into it | To mirror your GreenNotes appointments into your Google Account as you book, move or cancel them, so they appear on your phone and laptop alongside everything else. It gives GreenNotes no ability to read or change any other calendar | The separate GreenNotes calendar in your Google Calendar, and the calendar connection controls in your GreenNotes settings |
calendar.events.readonly | From the events in your primary Google calendar: the event identifier, its status, its start and end times and its free/busy status — and its title only if you switch on Show event titles in My Account. We do not receive event descriptions, locations or attendees | To show your existing commitments as busy time in the GreenNotes calendar so that you do not double-book. This permission is read-only: GreenNotes cannot write to, edit or delete anything in your primary calendar | Busy time on the Calendar screen in the web portal and in the iOS and Android apps |
We request nothing beyond the above. In particular, we do not request access to Gmail, Google Drive, Google Contacts, Google Photos, Google Tasks, your Google Ads or Google Analytics accounts, or any other Google service, and we do not request Google Calendar permissions wider than the two described above — GreenNotes cannot read the descriptions, locations or attendees of your events, and cannot create, change or delete anything outside the separate GreenNotes calendar it makes. We never receive, see or store your Google password: authentication happens on Google’s own systems, and Google returns only an access token to us.
We use Google user data only to provide and improve the user-facing features listed in the table above, namely:
We do not use Google user data for any other purpose. Specifically, we do not use it for advertising, marketing, profiling, credit assessment, resale, or to build any product other than the features you connected it for.
GreenNotes’ use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In plain terms, we commit to all four of the following:
Google user data is never used to train artificial intelligence or machine learning models. The Google user data described in this section is not sent to the AI providers listed in section 6, and is not used to train, fine-tune, evaluate or otherwise improve any AI or machine learning model, whether ours or a third party’s.
We do not sell, rent or trade Google user data, and we do not disclose it to third parties for their own purposes. We disclose it only in these limited circumstances:
You can withdraw our access to your Google data at any time, in either of two ways:
Withdrawing access does not affect the lawfulness of processing carried out before you withdrew it. If you would like us to confirm that your Google user data has been erased, or to request its deletion directly, email our Information Officer at david@greennotes.co.za and we will action and confirm the request.
If we ever wish to use Google user data for a purpose that is not described in this section, or to request additional Google permissions, we will update this section, notify you, and where the law or the Google API Services User Data Policy requires it, obtain your consent before the new processing begins.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are as follows:
The providers that may process practice and patient information are named, with what they do and where, on our Sub-processors page.
Our system of record, meaning the database and file storage, is hosted in South Africa (Google Cloud, Johannesburg). Some processing takes place in other countries:
The countries and providers currently involved are listed on our Sub-processors page.
Where we transfer personal information to a recipient outside South Africa, we do so in accordance with section 72 of POPIA. We require each recipient, by written agreement, to provide protection substantially similar to POPIA’s conditions for lawful processing, including restrictions on further transfers, or we rely on another basis that section 72 permits. For our AI providers these agreements are Google’s Cloud Data Processing Addendum and Groq’s Customer Data Processing Addendum, neither of which allows the provider to use the information to train its AI models. Section 9 of our Data Processing Agreement has further detail. Where a practice uses GreenNotes, the practice, as the responsible party, decides whether to use the features that involve these transfers, and informs its patients.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
Consent first. When you first visit our website we show a cookie banner. The third-party analytics and advertising technologies listed below only set cookies or store identifiers if you choose “Accept”. Three of them send a cookieless measurement signal before you answer the banner: Ahrefs, which is cookieless by design; the Google tag, which runs in a cookieless “consent denied” mode until you accept; and a cookieless page-view ping to Meta, described below. None of these stores a cookie or an identifier for you on our website. Our own sign-up attribution, at the end of this section, works differently. You can change or withdraw your choice at any time using the floating cookie icon in the bottom-left corner of the site.
Microsoft Clarity. With your consent, we use Microsoft Clarity to understand how visitors use our website through heatmaps and session replays (mouse movement, scrolling and clicks). Clarity masks the content of text you type by default. For more information, see the Microsoft Privacy Statement.
Meta (Facebook) Pixel. We use Meta measurement to understand how effective our advertising is. This works in two stages.
Meta Conversions API (server events). To measure our advertising, our servers also send some events to Meta directly:
These events never include patient information.
For more information, see Meta’s Privacy Policy.
Leadfeeder. With your consent, we use Leadfeeder to identify the companies (not individuals) that visit our website, based on IP address, to inform our business-to-business sales outreach. For more information, see the Leadfeeder Privacy Policy.
Google Analytics & Google Ads. We use Google Analytics to understand how our website is used, and Google Ads to measure the effectiveness of our advertising (such as whether an advert led to a free-trial signup or a demo registration). The Google tag uses Google’s Consent Mode: until you accept cookies it operates in a cookieless, consent-denied state and stores no identifiers; if you accept, measurement cookies are set. For more information, see the Google Privacy Policy.
Ahrefs Analytics. We use Ahrefs Web Analytics for aggregate, privacy-friendly page statistics. It does not use cookies and does not track you across sites.
Currency detection (ipapi.co). When you open our home page or pricing page, your browser asks ipapi.co which country your IP address is associated with, so that we can show prices in rand or US dollars. This sends your IP address to ipapi.co whether or not you have answered the cookie banner. It sets no cookie, and we do not store the result. For more information, see the ipapi.co privacy policy.
Our own sign-up attribution (first party). Your browser keeps the record of how you found us (section 1) on our website and web portal:
gn_aid cookie, which greennotes.co.za and app.greennotes.co.za share, so that a later visit, or a visit to the other site, adds to the same record. After you sign up, the web portal also sets a gn_rot cookie, so that the next sign-up on the same computer starts a fresh record, apart from a note of this browser’s first visit. Each cookie expires 395 days (about 13 months) after it was last set.Declining cookies does not stop the record itself, because we rely on our legitimate interest for it rather than on your consent. Section 10 explains how to object to it.
As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions.
We provide AI Products through these third-party service providers:
Our AI Products are designed for the following functions:
Our AI Terms of Use describe these features in more detail.
We keep personal information only for as long as it is needed for the purposes in this Privacy Policy, unless the law requires or permits a longer period. How long depends on the category of information and why we hold it:
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We maintain technical and organisational safeguards appropriate to the nature and sensitivity of the information we process, as described further in our Data Processing Agreement. No information system can eliminate every security risk, so we cannot guarantee that unauthorised people will never defeat these safeguards. Customers also have responsibilities for securing their accounts, users and devices.
Where we act as an operator and become aware of a security compromise affecting personal information we process for a practice, we notify the practice in accordance with our Data Processing Agreement, so that it can meet its obligations under POPIA. Where we act as the responsible party, we make the notifications that POPIA requires of us.
GreenNotes is used by healthcare practices and their staff. We do not market to children, and you must be at least 18 years old to create an account. If we learn that an account belongs to someone under 18, we will deactivate it.
Practices may keep records about patients who are children. We process that information only as the practice’s operator, under our Data Processing Agreement, with the same protections as other health information. The practice, as the responsible party, is responsible for having a lawful basis for processing a child’s personal information under POPIA, including the consent of a parent or guardian where that is required. Questions can be sent to help@greennotes.co.za.
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the contact details provided in the section below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account.
Objecting to sign-up and enquiry attribution: We keep the record of how you found us (section 1) on the basis of our legitimate interest, and you may object to it at any time by contacting our Information Officer (section 14). We will then delete its advertising click identifiers, any other copies of your marketing attribution that we hold and the enquiries you sent us through our forms, and mark the rest of the record so that it is left out of our reporting. To stop your browser keeping its copy, decline cookies and close the tab, or clear your browser’s storage for our sites.
If you would at any time like to review or change the information in your account or terminate your account, you can email us at help@greennotes.co.za.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
If you are a resident of South Africa, you have the right to access the personal information we hold about you and to request that it be corrected, updated, or deleted. If you wish to exercise this right, please contact us using the contact details provided at the end of this Privacy Policy.
In terms of the Promotion of Access to Information Act, 2000 (PAIA), you have the right to request access to records held by us. Our PAIA Manual, which contains details on how to submit a request for access to information, is available upon request or on our website.
If you are unsatisfied with the manner in which we handle any privacy concern or complaint, you have the right to lodge a complaint with the Information Regulator (South Africa):
Information Regulator (South Africa)
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
If you have questions or comments about this policy, you may contact our Information Officer:
Information Officer
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information.
These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please contact us using the details provided above. For access to records held by us in terms of the Promotion of Access to Information Act, 2000, please refer to our PAIA Manual available upon request or on our website.