Privacy Policy

Last updated: November 7th, 2022

Introduction

healthtracka.com is provided by Healthtracka (“Healthtracka”).

At Healthtracka, we value your privacy, and we are committed to safeguarding your personal information. All personal data that you provide us will be protected and kept confidential among our affiliates, representatives, and privies.

Throughout the website, the terms “we”, “us” and “our” refer to Healthtracka.

This Privacy Policy explains how we collect, use, share and protect your personal data in connection with your use of our services. This policy also sets out your rights and whom you may contact for further information.

You agree to this Privacy Policy by visiting our website and when you use our services.

Your use of our services, and any dispute over privacy is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this Policy.

Our website is hosted in Nigeria and is subject to the laws of the federal republic of Nigeria. If you are accessing our website from other jurisdictions, please be advised that you are transferring your personal information to us in Nigeria, and by using our website, you are agreeing to the transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of the federal republic of Nigeria concerning your use of the website and your agreements with us.

Our website and services are not directed at you if we are prohibited by any law of any jurisdiction from making the information on our website available to you and is not intended for any use that would be contrary to local law or regulation.

Consent

Where processing of your personal data is based on consent, we shall obtain the requisite consent at the time of collection of the personal information. In this regard, you consent to the processing of your personal information when you access our website, or use our services, content, features, technologies or functions offered on our website or other digital platforms. You can withdraw your consent at any time but such withdrawal will not affect the lawfulness of the processing of your data based on consent given before its withdrawal.

Where your personal data is to be processed for a different purpose that is incompatible with the purpose or purposes for which that personal data was originally collected that was not disclosed to you when you first provided your consent, we will obtain your consent to the new purpose or purposes.

Age Restriction

You affirm that you are over 18 years old and have the right to contract in your own name, and that you have read the above authorisation and fully understand its contents.

Individuals under 18 years old are only allowed to sign up for our services or provide us with their information when an adult above the age of 18 is signing contracts in their stead.

Data Protection Policies

The Data Protection Legislation sets out the following principles with which anyone handling personal data must comply. We, our employees, agents, contractors and third-party service providers comply with the following principles when collecting or processing your personal data. All personal data must be:

• • Processed lawfully, fairly, and in a transparent manner in relation to the data subject;
• • Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;
• • Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay;
• • Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection Legislation in order to safeguard the rights and freedoms of the data subject;
• • Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

Information We Collect

In providing our educational services to you, we collect certain non-personal and personal data about you. Our policy is to keep this information confidential and strictly safeguarded, and to use or disclose it only as needed to provide services to you, or as permitted or required by the Data Protection Legislation.

There are two categories of information we collect. We collect a variety of information from our users and visitors to our website. As described below, some information is automatically collected when you visit our website, and some you provide to us when filling out a form or communicating with us.

1. Information collected automatically: Whenever you visit our website, our web servers automatically collect non-personal information such as the domain name of the internet access provider, the internet protocol address used to connect the computer to the internet, the average time spent on our website, pages viewed, information searched for, access times, and other relevant statistics.
2. Information you provide us: If you provide us with personal information, by contacting us, or subscribing to our services we collect the following personal information:
• • Username and password;
• • Contact information;
• • Information concerning your identity e.g. a valid government-issued identity card and your nationality;
• • Test samples;
• • Health record;
• • Test results; and
• • Any other information you provide to us

Using Your Personal Data

We primarily collect your personal data to ensure that we provide the most efficient diagnostic service to you, monitor the use and improve our website and other legitimate interests. Your information will solely be used and disclosed for the following purposes:

• • To help us verify your identity;
• • To carry out our obligations ensuing from any contracts entered into between you and us;
• • To provide you with the products, services and information you request from us, including sharing your information with doctors, partner labs, regulatory bodies, or pharmacies where we have legal basis to do so;
• • To receive, store and analyze your samples at accredited laboratories;
• • To receive, review, store and communicate your test information to you, including by presenting your test information and other reported history via e-mail or secure result dashboard;
• • To provide you with your results and, in some instances, relevant treatment options;
• • To retain certain records about the handling of any samples you send us for regulatory purposes;
• • To assist you with enquiries and improve our customer service;
• • To assist us in carrying out marketing analysis and customer profiling (including transactional information), conduct research, including creating statistical and testing information;
• • To allow us to communicate with you in any way (including e-mail, telephone, visit, and text or multimedia messages);
• • For our billing and account purposes;
• • To help prevent and detect fraud or loss;
• • To update our records;
• • To make recommendations and suggestions to you about services offered by us unless you have previously asked us not to do so;
• • To send you service or support messages, such as updates, security alerts, email notifications and /or newsletters;
• • To conduct investigations and risk assessments; and
• • For compliance with legal and regulatory obligations.

Employees, agents, contractors, or other parties working on behalf of Healthtracka shall collect your personal data only to the extent required for the performance of their job duties and only in accordance with this policy. Excessive personal data must not be collected.

Employees, agents, contractors, or other parties working on behalf of Healthtracka shall process your personal data only when the performance of their job duties requires it. Your personal data held by Healthtracka cannot be processed for any unrelated reasons.

Data Accuracy

Your personal data must be accurate and kept up to date. In this regard, Healthtracka shall ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to you; make efforts to keep your personal data updated where reasonable and applicable; and make timely efforts to correct or erase your personal data when inaccuracies are discovered.

Data Retention

Healthtracka shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed. In the case of your health data, the purpose for which the data was collected is to provide you with our diagnostic services. Unless Healthtracka receives a valid request to erase your health data, the data is retained permanently. This allows your record of test information and samples to be maintained. If the data were deleted, we would have no record of your test information and samples to be maintained.

Other Information We Collect

Other information which may be automatically collected from you when you visit our website include domain name of your internet service provider, the internet protocol address used to connect the computer to the internet, the average time spent on our website, pages viewed, information searched for, access times, your geographical location, operating system, referral source, and other relevant statistics.

We may also collect information from you using cookies and other analytical tools especially when you use our products and services. More details are provided below in our section on Cookies.

Data Confidentiality

Your information is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions. You have the right to request copies of any and all information we keep on you, if such requests are made in compliance with applicable laws and other relevant enactments. While we are responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our premises, dealing with only authorized officers of Healthtracka.

Disclosure

We will not sell, publish, or disclose to third parties your personal data collected on our website, through our servers or otherwise obtained by us, other than to provide our services and as set forth in this policy. We may share generic aggregated demographic information not linked to any personally identifiable information regarding visitors and users with our business partners, trusted affiliates, professional advisers and advertisers for the purposes outlined above. We may share your information with these third parties for those limited purposes if you have given us your permission and in compliance with the Data Protection Legislation.

We may request and provide Personally Identifiable Information about you from and to third parties to provide our services. We may share personally identifiable information with service providers, healthcare providers, affiliates, partners, and other third parties where it is necessary to provide the products and services, or for any other purposes described in this Privacy Policy.

Your Personally Identifiable Information may be provided as necessary to the following categories of recipients: accredited laboratories, healthcare providers, pharmacies, service providers (such as couriers, communications and marketing service providers, IT-related service providers, analytics providers, legal or financial advisors, contractors and vendors), and other trusted third parties with whom we have an agreement for the protection of your information, or government/regulatory/law enforcement agencies pursuant to legally binding order.

We may disclose and transfer your Personally Identifiable Information to our accredited laboratory for the purpose of (i) accepting and processing an accepted order by us, (ii) in order to ensure the tests are analysed and (iii) to test any sample provided and make your test information available to you via mail or on our secure result dashboard on our Site and Platform. To process a request for a test and for our accredited laboratory to test the sample and send you the test information, we need to disclose personal information within and outside our company including to healthcare providers, to our accredited laboratory and our IT services providers.

We may disclose and transfer your Personally Identifiable Information to healthcare providers, such as contracted or other medical practitioners for purposes of review, quality assurance, prescribing of tests, review of results and other purposes.

We will notify you as soon as we become aware of a harmful data breach which may result in a risk of your rights and freedom.

You have the right to request an erasure of your data at any time.

We will notify you if we are transferring your data.

You may request at any time that we halt further dissemination of your data or cease to use your data.

We may disclose Personally Identifiable Information if required to do so by law or in the good faith belief that such action is necessary to (a) conform with the requirements of the law or comply with legal process served on us, or (b) act in urgent circumstances to protect the personal safety of users of our service or members of the public.

To the extent practicable and legally permitted, we will attempt to advise you prior to any such disclosure, so that you may seek a protective order or other relief limiting such disclosure.

Transfer of Personal Data

Your Rights

Subject to certain limitations and exceptions, you are entitled to the following principal rights under the Data Protection Legislation:

• • You have the right to be notified if we are transferring your personal information.
• • You have the right to request an erasure of your personal data at any time.
• • You have the right to request that we rectify inaccurate personal information.
• • You may request at any time that we halt further dissemination of your data or cease to use your personal information.
• • You have the right to request for copies of your personal information.

Website Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as secure sockets layer (SSL) to safeguard and secure the information we collect online. We use encryption tools when accepting and transmitting delicate visitor information through our website. Some of the other safeguards we use are firewalls and physical access controls to our data centres, and information access authorization controls.

Training

We shall ensure that employees who collect, access and process your personal data receive adequate data privacy and protection training in order to develop the necessary knowledge, skills and competence required to effectively manage the compliance framework under this policy and the Data Protection Legislation with regard to the protection of personal data. On an annual basis, we shall develop a capacity building plan for our employees on data privacy and protection in accordance with the Data Protection Legislation.

Use of Cookies

We use cookies to identify you as a user and make your user experience easier, customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies allow our servers to remember your account log-in information when you visit our website, IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities. If your browser or browser add-on permits, you have the choice to disable cookies on our website; however, this may limit your ability to use our website.

The Data We Retain

We will retain your information for as long as needed to provide you with our services, comply with our legal and statutory obligations or verify your information with a financial institution.

We are statutorily obligated to retain the data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud and in compliance with laws and regulatory guidelines applicable to us.

Data Breach Management Procedure

In the event where there is any accidental or unlawful destruction, processing, loss, alteration, unauthorized disclosure of, or access to your personal data, we shall:

• • Notify you within 24 hours of the occurrence of the data breach;
• • Properly investigate the breach and take the necessary steps to mitigate such breach;
• • Identify remediation requirements and track the resolution of such breach; and
• • Notify the Information Commissioner’s Office or any other regulatory authority, where necessary.

Data Confidentiality

Our website may contain links to third-party websites or services that are not owned or controlled by us.

We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such websites or services.

We strongly advise you to read the terms and conditions and privacy policies of any third-party websites or services that you visit.

Limitation of Liability

We exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, we will not be liable for unauthorised disclosure of personal data that occurs through no fault of ours.

Changes to this Privacy Policy

Changes may be made to this Privacy Policy from time. Whenever such changes are made, we will notify you. These changes will take effect immediately after you have been notified.

Data Confidentiality

If you would like more information or you have any comments or questions on our Privacy Policy, please contact us at hello@healthtracka.com.

This policy is effective as of October 6th, 2022.

Last updated: October 6th, 2022.