Nguvu Health is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, Nguvu Health is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data” or "personal identifiable information") collected online. This document is our privacy policy (“Privacy Policy”) and it contains details on the issues related to your privacy when using our services. Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals. Please read this Privacy Policy carefully to understand and learn more about our views, policies, procedures and practices regarding the collection of information and personal information, how we collect, use, share, disclose and protect the personal information that we have obtained through the use of our platform. This policy (together with our Terms of use) sets out the basis on which any personal data we collect from you, or that you provide, will be processed by us. By accessing and continuing to visit our website www.nguvuhealth.com and use our services, you accept and consent to the practices described in this policy and our terms and conditions. If you do not agree to be bound to this Privacy Policy, you should stop using the platform immediately.

What information we collect

In order for us to operate the website effectively and to allow you use the website, including having a session with a Therapist, we may obtain personal identifiable information about you if you choose to provide it in the course of our business— for example, to register for certain services. In some cases, you may have previously provided your personal information to Nguvu Health. If you choose to register or login to the Nguvu Health website using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, Instagram, Twitter etc.) with Nguvu Health, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect may depend on the privacy settings you have set with your social media provider, so please review the privacy policy of the applicable service. By registering and/or submitting personal information to Nguvu Health, you are also acknowledging that Nguvu Health may use this information in accordance with this Privacy Policy. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted to by law or professional standards. For example, if you register to the Nguvu Health website and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third-party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience. In some cases where you have registered for certain services we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request). The personally identifiable information that we may process include but is not limited to: Basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person Contact information, such as your postal address, email address and phone number(s), house or office address, billing and payment information, profile information, log data. Technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically, Internet Protocol address Information you provide to us for the purposes of using our services, information related to the Therapist Services or your need for a Therapist, any information exchanged between you and your Therapist. Information relating to your health such as blood group, genotype, health history or other health related data etc. Personal information provided to us by or on behalf of our users or generated by us in the course of providing services to them. Personal information provided to us by third parties. Any other information relating to you which you may provide to us. By deciding to provide any of the information above you agree to our methods of collections and use, as well to other terms and provisions of this Privacy Policy.

The legal grounds we have to use your personal information

Nguvu Health generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection. The law in Nigeria allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions: The performance of a contract, this is when the processing of your personal information is necessary in order to perform our obligations under a contract or for us to take steps at your request A Legal obligation, this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; Legitimate and Vital interests, we may process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or in order to protect your vital interest or of another natural person. Your consent is given, we may occasionally ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting (talk@nguvuhealth.com.) Where it is necessary for the performance of a task carried out in the interest of the public or in the exercise of an official public mandate vested in us. Nguvu Health only collects "sensitive" personal information when you voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person's race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record. Please use your discretion when providing sensitive information to Nguvu Health, and under any circumstances, do not provide sensitive information to Nguvu Health, unless you thereby consent to Nguvu Health's use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in Nguvu Health databases. If you have any questions about whether the provision of sensitive information to Nguvu Health is, or may be, necessary or appropriate for particular purposes, please contact (talk@nguvuhealth.com.) Your personal information is used in: Updating and enhancing Nguvu Health's records. Creating your account on the Nguvu Health platform and let you log in to your account and use the platform. Managing your account, providing you with customer support, and ensuring you are receiving quality service. Executing your instructions and billing related services. Matching you with a Therapist and facilitating Therapist services. Reaching out to you, either ourselves or using the appropriate authorities, if either we or a Therapist have good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act. Establishing your identity and assessing applications for our products and services. Personalizing your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email or text message (with your consent, where required by law). Contacting you and providing you with information, alerts and suggestions related to our products and services. Managing our relationship with you and monitor the service being provided. Managing our risks. Contacting you, for example in instances where we need to schedule an appointment for you with any of our therapists with or when the need arises to give you information or tell you about some event(s) of significance. Conducting and improving the quality of our businesses and improving the effectiveness and delivery of our service and your experience with us. Complying with our legal obligations and assisting government and law enforcement agencies or regulators/supervisors. Identifying and informing you about other products or services that we think may be of interest to you. Processing your job application if you apply for a job with us via our website. We may also collect, use and exchange your information in other ways permitted by law.

Services

The licensed therapists who deliver services through Nguvu are independent professionals/ contractors. Nguvu, does not practice medicine or any other licensed profession, and does not interfere with the practice of medicine or any other licensed profession by healthcare professionals, each of whom is responsible for his or her services and compliance with the requirements applicable to his or her profession and license. Neither Nguvu nor any third parties who promote the services or provide you with a link to the services shall be liable for any professional advice you obtain from a licensed therapist while using the Nguvu Health website.

IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

Cookies and Web Beacons

Cookies are small text files stored on your computer or mobile devices whenever you visit a website. Cookies have many uses, such as memorizing your preferences to tailor your experiences while on our site– or to help us analyze our website traffic. A web beacon is a tiny image, placed on a web page or email that can report your visit or use. Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves several purposes. On some of our websites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user-input" cookies may still be required for necessary functionality. Such cookies will not be blocked using this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies. Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our websites' features. Other third-party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly. Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our websites and geographic origin of visitor trends, and not to identify individual visitors. There may also be the use of cookies and web beacons of services owned or provided by third parties that are not covered by our Privacy Policy and we do not have access or control over these cookies and web beacons. We may also use third party cookies for the purposes of web analytics, attribution and error management. BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

Location-based tools

Nguvu Health may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

Social media widgets and applications

Nguvu Health websites may include functionality to enable sharing via third party social media applications, such as the Facebook, Google+ Instagram, Twitter etc. Any personal information that you provide via such social media applications or tools may be read, accessed, collected and used by users of that social media application or site and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information. In addition, Nguvu Health websites may host blogs, forums, crowd-sourcing and other applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any Nguvu Health social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control. Nguvu Health may interact with registered users of various social media platforms, including Facebook, Twitter, Google+, LinkedIn and Instagram etc. Please note that any content you post to such social media platforms (e.g. pictures, information or opinions), as well as any personal information that you otherwise make available to users (e.g. your profile) is subject to the applicable social media platform’s terms of use and privacy policies. We recommend that you review this information carefully in order to better understand your rights and obligations regarding such content.

Children

Nguvu Health understands the importance of protecting children's privacy, especially in an online environment. Our sites are not intentionally designed for or directed at children under the age of 18. It is our policy never to knowingly collect or maintain information about anyone under the age of 18, except as part of an engagement to provide professional services or with the express permission or supervision of their parents or guardians. If you are aware that we have collected personal identifiable information from a child under age 18, please let us know by contacting us via talk@nguvuhealth.com and we will delete that information.

Sharing and transfer of personal information

Transfers to third parties We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This would include: Our service providers: Nguvu Health works with reputable strategic partners, service provider or agencies so they can process your personal information on our behalf. Nguvu Health will only transfer personal information to them when they meet our strict standards on the processing of data and security. We only share personal information that allows them to provide their services. If we are reorganized or sold to another organization: Nguvu Health may also disclose personal information in connection with the sale, assignment, merger or other transfer of the business of the site to which the data relates; Courts, tribunals, law enforcement or regulatory bodies, government agencies: Nguvu Health may disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules or government regulations. Audits: disclosures of personal information may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. In addition, Nguvu Health may transfer certain personal information within and outside Nigeria to offshore companies working with us or on our behalf for the purposes described in this Privacy Policy. Nguvu Health may also store personal information within and outside Nigeria. If we do this, your personal information will continue to be protected by means of contracts we have in place with those organizations outside Nigeria. By providing personal information online, visitors are consenting to this transfer and/or storage of their personal information across borders. Nguvu Health may employ third party companies and individuals to facilitate to perform certain tasks which are related to the website, or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements. Nguvu Health will not transfer the personal information you provide and information about your usage of our website to any third parties for their own direct marketing use. We do not disclose any information about any user’s usage of our web site except in specific cases, and we do not share information with any unaffiliated third parties for marketing purposes unless you expressly give us permission to do so.

Choices

In general, you are not required to submit any personal information to Nguvu Health, but we may require you to provide certain personal information for you to receive additional information about our services and events. Nguvu Health may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for certain services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request. As described in "Cookies" above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

Your rights

If you have submitted personal information to Nguvu Health, you have the following rights: Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect or incomplete, you may ask us to correct or rectify any inaccuracies in the personal information. Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it anymore, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances. You have the right to withdraw your consent for processing in cases where consent has previously been given. You also have the right to request that your information be erased. We might continue to retain such data if there are valid legal, regulatory or operational reasons. You can make a request or exercise these rights by contacting Nguvu Health at (talk@nguvuhealth.com ) and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

Data security and integrity

Nguvu Health has reasonable security policies and procedures and has organizational measures in place to protect personal information from unauthorized loss or access, misuse, modification, alteration, destruction or disclosure under our control. This may include the use of encryption, access controls and other forms of security to ensure that your data is protected. Where we have provided you (or where you have chosen) a password which grants you access to specific areas on our site, you are responsible for keeping this password confidential. We request that you do not to share your password or other authentication details (e.g. generated codes) with anyone. Despite Nguvu Health's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. We also make reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual's request , for the purpose it was collected or until that person asks that the information be deleted and, in any case, when such information is no longer necessary. The storage of your data is also determined by legal, regulatory, administrative or operational requirements.

Links to other sites

Please be aware that Nguvu Health websites may contain links to other websites, services or offers including sites maintained by third parties that are not governed by this Privacy Policy but by other privacy policies that may differ somewhat. We encourage users to review the privacy. If you click on a third-party link, you will be directed to that third party's website or service. The fact that we link you to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services, and we do not have control over their privacy policies and terms of use. Please review the privacy policy of each website visited before disclosing any personal information.

Changes to this Policy

Nguvu Health may modify this Privacy Policy from time to time on an ad-hoc basis to reflect our current privacy practices as well as the legal, regulatory and operating environment and such revised versions will automatically become applicable to you. When we make changes to this statement, we will revise the "updated" date at the top of this page and such revised policy becomes effective as at the time it is posted. We encourage you to periodically review this Privacy Policy to be informed about how Nguvu Health is protecting your information.

Policy questions and enforcement

Nguvu Health is committed to protecting the online privacy of your personal information. If you have questions, comments or requests about our administration of your personal information, please contact us at (talk@nguvuhealth.com ). You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Policy. We will acknowledge your email within [14] days and seek to resolve your concern within [3] months of receipt. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds. "Nguvu Health," "we," "our," and "us" refers to Nguvu Health Limited ("Nguvu"), a limited liability company registered under the laws of the Federal Republic of Nigeria, its subsidiaries and other partnerships, corporations, undertakings and entities which are authorized to do business using the name “Nguvu Health”.