1. Our Privacy Commitment

Telemedical is committed to being open and transparent about how we manage your personal information.

Our Privacy Policy aims to communicate, in the clearest way possible, how we treat your personal information. We encourage you to read this Privacy Policy carefully. It will help you make informed decisions about sharing your personal information with us.

At Telemedical we have a few fundamental principles:

• We will always collect, store, process, use, and disclose personal information by all applicable privacy laws and principles. However, we have also put in place this Privacy Policy to protect the personal information you submit or we collect.
• We will only process your personal information when it is necessary for us to deliver our services or perform other necessary business functions and activities.
• We will not use or disclose your personal information for purposes unrelated to our business activities and the services we provide unless we first obtain your consent.

2. Privacy Policy

This Privacy Policy sets out how we comply with our privacy obligations to those persons with rights under the Nigerian Data Privacy Regulation 2019 (NDPR) or the European Union General Data Protection Regulations for information received through our website and Insight (customer portal), as well as sectoral-specifically under the National Health Act 2014.

We are bound by the requirements of those laws, which regulate how we may collect, store, use, access, and disclose your personal information. Those laws also specify other requirements, such as how individuals may access, correct, erase and delete information held about them.

When we say “personal information” we mean identifiable information about you, such as your name, email, address, telephone number, work experience, qualifications, and so on.

By using our Services or providing your personal information to us, you consent to our collection, storage, use and disclosure of your personal information (and any sensitive information you provide) by this Privacy Policy.

3. Changes to this Privacy Policy

We may amend the terms of this Privacy Policy from time to time and will notify you of any changes by posting an updated version on our website or by sending you a notice via email. It is your responsibility to check this Privacy Policy periodically for changes and to keep your email address information with us current and up to date.

Your submission of personal information or continued use of our Services following notification of any changes to this Privacy Policy constitutes acceptance of those changes. If you do not agree with any aspect of the updated Privacy Policy, you must not submit your personal information to us (and you must immediately cease all use of our Services).

4. What Information do we Collect?

Information you provide to us directly: Our usual practice is to collect personal information directly from you, when you complete any form, including online forms, register to use our Services, or provide any other information in connection with your use of our Services. A few examples include and are not limited to the following:

• Personally identifiable information, including but not limited to, name, date of birth, gender, height, weight, phone number, email address, house address, blood type, and profile picture
• Medical information, including but not limited to, alcohol consumption, dieting, diabetes status, blood pressure, blood sugar, cholesterol, smoking status
• Information necessary for financial processes such as billing, including but not limited to, credit/debit card information, city, state, and so on.

Information we get from third parties: We collect or obtain personal information from authorized third parties (e.g., administrators of our Services, medical practice managers, or such other parties we engage to assist us with functions such as mail-outs or to assist us in providing our Services).

Information we collect automatically: We may collect personal information about you automatically when you visit our websites or use our Services, such as your IP address and device type. Some of this information may be collected using cookies and similar tracking technologies.

Information we create in the performance of the Services: We may also create or obtain personal information, such as evaluative records about your interactions with us. Evaluative information may be confidential to us.

You can always choose not to provide your personal information to us, but it may mean that we are unable to provide you with our Services.

The following are instances when we collect your data:

• Register online or place an order for any of our products or services.
• Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
• Correspond with us by phone or email.
• Join an email mailing list.
• Request support from our customer support team.
• Use or view our website via your browser’s cookies.
• You have applied for a job with us.
• Complete a symptom assessment or diagnosis
• Book an appointment or order a repeat prescription with us
• Fill in your medical history
• Track your vitals (blood pressure, blood sugar, etc.)

5. How is Your Personal Information Processed?

Where we collect personal information or sensitive information, we will only process it:

• to perform our Services; or
• where we have legitimate interests to process the personal information or sensitive information and these interests are not overridden by your rights; or
• when it is necessary for the protection of your vital interest or the interest of another person; or
• by a legal obligation; or
• where we have your consent.

We use and disclose your information for the normal business activities prescribed by law ranging from treatment, payment, and healthcare operations. Below are examples of those activities, which are however not exhaustive –

Treatment – We keep a record of the health information you provide us. This record may include your test results, diagnoses, medications, your response to medications or other therapies, and information we learn about your medical condition through our service platforms. We may disclose this information so that other doctors, nurses, and entities such as laboratories can meet your healthcare needs.

We collect your personal information so that we can provide you with the Services and any related services you may request. In doing so, we may use the personal information we have collected from you for purposes related to the Services including but not limited to these outlined below:

• to process and administer the Services, and to help us develop, improve, manage, administer, and facilitate our Services and business operations;
• to contract with authorized individuals (such as medical practice managers);
• to process your personal information for our internal business purposes;
• for general internal purposes (such as record keeping, database management, training, billing);
• assist with the resolution of any issues relating to the Services;
• comply with all laws and regulations in all applicable jurisdictions; and
• communicate with you.

By using our Services, you consent to your personal information and sensitive information being collected, processed, stored, accessed used, and disclosed in this way and for any other use you authorize. We will only use your personal information for purposes described in this Privacy Policy, or with your consent.

6. In What Very Limited Circumstances Might We Disclose Your Personal Information??

Your personal information will not be sold, traded rented, or otherwise provided to others without your consent.

We will only disclose your personal information outside Telemedical and its related companies if it is necessary and appropriate to facilitate the purpose for which your personal information was collected and processed under this Privacy Policy, including the provision of the Services, or a directly related purpose. This may include, for example, disclosure of personal information to:

• related companies to …. to enable the development and marketing of our other products and services and to improve our customer service in general;
• third-party service providers, including any sub-contractors, to enable us to provide our Services; and

We will not otherwise disclose your personal information unless we believe on reasonable grounds that you have provided your authorization. However, you should be aware that we may be required to disclose your personal information without your consent to comply with any court orders, subpoenas, or other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.

7. International Data Transfers

When we disclose data, it may be transferred to, and processed in, countries other than Nigeria – such as any other country where our data hosting servers are currently located. There may be differences in those other countries’ privacy laws. However, rest assured, that when we disclose personal information to a third party in another country, we place safeguards to ensure your personal information is protected.

By the provisions of the NDPR, should your personal data be intended for processing in a foreign country, the same will only be done under the supervision of the Attorney General of the Federation and where the NITDA has decided that the foreign country, territory, or one or more specified sectors within that foreign country, or the international organization in question ensures an adequate level of protection. Please consult the National Information Technology Development Agency (NITDA) or the NDPR (Regulation 2.11) for details of the necessary parameters allowing for the transfer of personal data to a foreign country.

8. Storage and Security

We are committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorized access, modification, or disclosure.

Telemedical implements and maintains security measures that are designed to provide reasonable protection against the loss, interference, or misuse of your personal information and to prevent unauthorized access, modification, or disclosure of that information.

9. What About Other Websites?

Our website may contain links to other websites that are not under our control. These other websites may use cookies. It is the responsibility of those third parties to collect appropriate consent from you to permit their cookies (to the extent this is required by law) and to inform you about the cookies they use. You should check the privacy policy on all third-party websites to ensure you are comfortable with third-party cookies.

We have no responsibility for linked websites and provide them solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices, and terms of use, and we make no endorsements, representations or warranties about their accuracy, content, or thoroughness. Your disclosure of personal information to third-party websites is at your own risk.

We may employ third-party companies and individuals due to the following reasons:

• To facilitate our Service
• To provide the Service on our behalf
• To perform Service-related services
• To assist us in analyzing how our Service is used.

We also want to inform users of this Service that these third parties have access to your Personal Information. However, they are obligated not to disclose or use the information for any purpose other than that which is assigned.

10. Email, Text, and Telephone Communications

We are committed to full compliance with the Nigerian Communications Commission Regulation 2011.

By subscribing to emails and/or text communications, or otherwise providing your consent to receiving emails and/or texts (as the case may be), you agree that we may send you emails and/or texts which promote and market our products and services, or the products and services of others, from time to time.

Where required, we will ensure we have your express consent before sending you such messages. You will always be able to unsubscribe from our email communications and/or text communications at any time by clicking the “Unsubscribe” link in any promotional or marketing email or text received or by email

Once you have unsubscribed from the email or text communications, you will be removed from the corresponding marketing list as soon as is reasonably practicable.

11. What Are Your Data Protection Rights?

Telemedical would like to make sure you are fully aware of all of your data protection rights. Users are entitled to the following:

• You have the right to ask us for copies of your personal information. There are some exceptions, which mean you may not always receive all the information we process. We may charge you a small fee for this service.
• You have the right to request that Our Company rectify any information you believe is inaccurate, false, or incomplete.
• You have the right to request that Our Company erase your personal data. This is however subject to prescribed conditions.
• You have the right to request that Our Company restrict the processing of your data, under certain conditions.
• You have the right to object to the processing of your data, under certain conditions.
• You have the right to ask that we transfer the information you gave us from one organization to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.
• Where we have obtained your consent to process your data or consent to send you information, you may withdraw your consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose, in which case we will inform you of this.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email – support@jeayhealthcare.com

Log Data

We want to inform you that whenever you use our Service, in the case of an error in the app we collect data and information (through third-party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.

Cookies

This Service does not use “cookies” explicitly. However, the app may use third-party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.

11. How You Can Access or Correct Your Personal Information

It is your responsibility to ensure that the personal information you provide is accurate, complete, and up-to-date.

You may request access to the information we hold about you, request that we update or correct any personal information we hold about you, ask us to restrict or cease processing your personal information, or even delete your personal information, by setting out your request in writing and sending it to us at

We will review your request as soon as reasonably practicable to comply with our legal obligations. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

12. Retention

The length of time we keep your personal information depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal requirements such as money laundering and financial reporting legislation). We do not store any data other than cookies on the device that you use to access our website.

We’ll retain your personal information for as long as we have a relationship with you and for a period afterward where we have an ongoing business need to retain it, by our internal retention policies and practices. Following that period, we’ll make sure it’s deleted or anonymized. Otherwise, as a general rule, we only keep your personal information for as long as we require it to provide you with our Services. Telemedical will ordinarily keep your data and personal information for at least 3 years which would be subject to review.

Disclaimer

We value your trust in providing us with your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security. This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

This Privacy Policy was last updated on the date above and replaces any other Privacy Policy previously applicable from this date.

Infant Privacy

These Services do not apply to anyone under the age of 13. We do not knowingly collect personally identifiable information and data from children under 13. In any event we discover that a child under 13 has provided us with personal information, we immediately delete this. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to take the necessary actions.

Your Rights

You can exercise your rights at any time by contacting us directly at support@jeayhealthcare.com

If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Policy, we may not be able to provide you with access to all or parts of our sites and platforms.

How to contact us

If you have any questions about Our Company’s privacy policy or the data we hold on you or would like to exercise one of your data protection rights, please do not hesitate to contact us through our Privacy Officer. We will respond as quickly as possible and handle all complaints in a way that is fair and consistent. However, if you remain dissatisfied, you can make a formal complaint with the Office of the Privacy Commissioner.

Email us at support@jeayhealthcare.com

How to contact the appropriate authorities

You also have the right to raise any concerns about how your personal data is being processed by us with the NDPR –

Email: info@ndpb.gov.ng

Address: No 5, Donau Crescent, Off Amazon Street, Maitama, Abuja, Nigeria

This represents our Privacy Policy as of March 2023.