Draft
TODO-LEGAL-REVIEW — This document is an outline awaiting legal review (including NDPA compliance). It is not the final text and must not be relied on.
Privacy notice
Privacy notice
How we handle your personal and health information. Draft outline pending legal review.
1. Who we are
Placeholder — final wording pending review.
- Controller identity and registered address
- Data Protection Officer contact details
2. Information we collect
Placeholder — final wording pending review.
- Account and contact details
- Health information you provide in questionnaires and messages
- Technical and usage data (first-party, no advertising trackers)
3. Sensitive personal data
Placeholder — final wording pending review.
- Health and sexual-health data treated as sensitive personal data under the NDPA
- Explicit consent and other lawful bases relied upon
4. How we use information
Placeholder — final wording pending review.
- Providing clinical care and pharmacy fulfilment
- Account, billing and support
- Service improvement using de-identified data
6. Cross-border transfers
Placeholder — final wording pending review.
- Where data is hosted and the safeguards applied
7. Retention
Placeholder — final wording pending review.
- Medical record retention periods
- Deletion of marketing and lead data
8. Your rights
Placeholder — final wording pending review.
- Access, correction, deletion, objection and portability
- Withdrawing consent and marketing preferences
- Complaints to the Nigeria Data Protection Commission
9. Security
Placeholder — final wording pending review.
- Encryption in transit and at rest
- Access controls and audit logging