Privacy Policy

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HYGEIA NIGERIA LIMITED PRIVACY POLICY

Hygeia Nigeria Limited (‘Hygeia’’) respects your privacy and takes its responsibilities
with regard to the management of personal data very seriously. We do not take lightly
the trust you have reposed in us, in providing us with your personal information.

This Data Privacy Policy (the “Privacy Policy”) describes how Hygeia processes your
Personal Data and is a guide to help you understand:

  1. The Information We Collect
  2. How We Collect and Use Your Personal Data
  3. Consent and Access Rights
  4. Personal Data Protection Principles
  5. User Responsibility
  6. Data Security
  7. Link to Third Party Websites
  8. Third-Party Access
  9. Violation of Privacy
  10. Data Retention
  11. How to Contact Us

Hygeia reserves the right to make changes to this Privacy Policy at any time and for any reason. You will immediately be notified about any changes and all changes will be effective immediately unless otherwise specified.

Hygeia’s obligations and the exercise of such obligations pursuant to this Data Privacy Policy shall be subject to its obligations under the Nigerian Data Protection Regulation 2019.

  1. The Information We Collect
    We collect the following information: name, date of birth, residential and contact
    address, telephone number, email address, marital status, nationality, gender,
    sexual orientation, tax identity number, credit and/or debit card information, which
    includes the card number, card expiry date, and card verification value/code, trade
    union membership, bank details, information posted on social networking
    platforms, information on family members, medical information, race or ethnic
    origin, political opinions, educational background, genetic data, biometric data,
    an identity number, location, photograph, IP address, MAC address, IMEI
    number, IMSI number and other relevant information which constitute Personal
    Data.
  2. How We Collect and Use Your Personal Data
    2.1 Hygeia collects the above-mentioned information using forms, email, physical
    requests, cookies, subscription to Hygeia’s newsletter, JWT, and web tokens.
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    2.2 When you send an email to Hygeia or use any other form of communication, we
    may retain the information from such communication in order to process your
    inquiries, respond to your requests and improve our services. When you access
    Hygeia’s services, our servers automatically record information that your browser
    sends whenever you visit a website.
    2.3 We use the above-mentioned information to obtain legal advice, provide services
    to you, for research, regulatory compliance, marketing, business development, to
    process donations, to send periodic emails, listing in directories, publicity, human
    resources management, recruitment, event planning and hosting, in-house
    security, and analysis, key business operation, processing or carrying out the task to
    fulfill Hygeia’s goals or objectives.
  3. Consent and Access Rights
    3.1 We require your consent for the processing of your personal data and where
    the document deals with several matters, we shall obtain your consent in a manner
    which clearly distinguishes it from the other matters in the document.
    3.2 Notwithstanding paragraph 3.1 above, we can process your personal data in the
    absence of consent where:
    a. processing is necessary for the performance of a contract to which you are a
    party or in order to take steps at your request prior to entering into a contract;
    b. processing is necessary for compliance with a legal obligation to which we
    are subject;
    c. processing is necessary in order to protect your vital interests or that of
    another natural person; and
    d. processing is necessary for the performance of a task carried out in the public
    interest or in the exercise of official public mandate vested in us.
    3.3 If we intend to use your personal data for a purpose which is different from the
    purpose for which your personal data was obtained, we will seek your consent
    prior to the use of your personal data for that other purpose.
    3.4 In the event of any arrangement whereby Hygeia sells or transfers all, or a
    portion of its business or assets (including in the event of a reorganization,
    dissolution or liquidation) to third parties, you hereby consent that your personal
    data held by Hygeia can be transferred or assigned to third parties who may
    become the controllers and/or processors of your personal data that was held by
    Hygeia prior to such arrangement. Hygeia shall at all times ensure that you are
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    notified when your personal data is intended to be transferred to third parties in
    the circumstances outlined in this clause. Hygeia will provide the third party with
    its Data Protection Policy and Privacy Policy and will not be responsible for the
    failure of the third party to honor the commitments made in this Privacy Policy
    and the Data Protection Policy.
    3.5 No consent shall be sought, given or accepted in any circumstance that may
    engender direct or indirect propagation of atrocities, hate, child rights violation,
    criminal acts and anti-social conducts.
    3.6 You may withdraw your consent at any time and may request access to your
    personal information in our possession. We can, however, deny you access to
    the information where we determine that your request is unreasonable. Where
    Hygeia has reasonable doubts concerning the identity of the person making the
    request for information necessary to confirm the identity of the person making the
    request.
    3.7 You reserve the right to request the deletion or modification/amendment or
    deletion of your personal data in our possession.
    3.8 In all cases of access deletion or modification/amendment or deletion of personal
    data, we shall request sufficient identification to enable us to confirm that you are
    the owner of the personal data sought to be accessed or modified/amended.
    Upon modification/amendment of personal data, Hygeia shall notify the requester
    of such the completion of the modification/amendment.
  4. Personal Data Protection Principles
    When we process your personal data, we are guided by the following principles,
    which require personal data to be:
    a) processed lawfully, fairly, in a transparent manner and with respect for the
    dignity of the human person.
    b) collected only for specified, explicit and legitimate purposes and not further
    processed in a manner incompatible with those purposes.
    c) adequate, relevant and limited to what is necessary in relation to the
    purposes for which it is Processed.
    d) accurate and where necessary kept up to date.
    e) removed or not kept in a form which permits identification of data subject for
    longer than is necessary for the purposes for which the personal data is
    processed.
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    f) processed in a manner that ensures its security, using appropriate technical
    and organisational measures to protect against unauthorised or unlawful
    Processing and against accidental loss, destruction or damage.
  5. User Responsibility
    You are required to familiarise yourself with this policy and to ensure that the
    information you provide to us is complete, accurate and up to date.
  6. Data Security
    6.1 Hygeia implements and maintains appropriate safeguards to protect personal
    data, taking into account in particular the risks to you, presented by unauthorised
    or unlawful processing or accidental loss, destruction of, or damage to your
    personal data.
    6.2 Safeguarding will include the use of encryption and pseudonymisation where
    appropriate. It also includes protecting the confidentiality (i.e. that only those who
    need to know and are authorised to use personal data have access to it),
    integrity and availability of the personal data. We regularly evaluate and test the
    effectiveness of those safeguards to ensure the security of our processing of
    personal data.
    6.3 You should be aware, however, that no method of transmission over the Internet
    or method of electronic storage is completely secure. While we strive to protect
    the security of your information and are constantly reviewing and enhancing our
    information security measures, we cannot guarantee absolute security. Hygeia,
    therefore, accepts no liability for any damage or loss, however caused, in
    connection with transmission over the Internet or electronic storage.
  7. Links to Third-Party Websites
    The Hygeia website may contain links to other websites owned and operated by
    third parties. These links are provided for your information and convenience only
    and are not an endorsement by Hygeia of the content of such linked websites or
    third parties. The information that we collect from you will become available to
    these websites if you click the link to the websites. These linked websites are
    neither under our control nor our responsibility. Hygeia, therefore, makes no
    warranties or representations, express or implied about the safety of such linked
    websites, the third parties they are owned and operated by and the suitability or
    quality of information contained on them. This Privacy Policy does not apply to
    these websites and we cannot guarantee the safety and privacy of your
    information, thus, if you decide to access these linked third-party websites and/or
    make use of the information contained on them, you do so entirely at your own
    risk. Hygeia accepts no liability for any damage or loss, however caused, in
    connection with accessing, the use of or reliance on any information, material,
    products or services contained on or accessed through any such linked website.
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    We advise that you contact those websites directly for information on their
    privacy policy, security, data collection and distribution policies.
  8. Third-Party Access
    8.1 Hygeia only shares personal information with other companies, entities or
    individuals in the following limited circumstances:
    a) We have your consent.
    b) We provide such information to other professional advisers or other trusted
    businesses or persons for the purpose of processing personal information on
    our behalf. We require that these parties agree to process such information
    based on our instructions and in compliance with this Privacy Policy and any
    other appropriate confidentiality and security measures.
    c) We strongly believe belief that access, use, preservation or disclosure of
    such information is reasonably necessary to (i) satisfy any applicable law,
    regulation, legal process or enforceable governmental request, (ii) enforce
    applicable terms of service, including investigation of potential violations
    thereof, (iii) detect, prevent, or otherwise address fraud, security or technical
    issues, or (d) protect against imminent harm to the rights, property or safety
    of Hygeia, its users or the public as required or permitted by law.
    8.2 Hygeia is at all times, responsible for the security and appropriate use of such
    personal data as long as it remains with Hygeia.
  9. Violation of Privacy
    9.1 We have put in place procedures to deal with any suspected personal data
    breach and may notify you of any significant breach to your personal data and let
    you know the steps we have taken to remedy the breach and the security
    measures we have applied to render your personal data unintelligible.
    9.2 All suspected breach of personal data will be remedied with 1 (one) month from
    the date of the report of the breach.
    9.3 If you know or suspect that a personal data breach has occurred, you should
    immediately contact the Data Protection Officer, Hygeia team at [•].
    9.4 Hygeia will not be responsible for any personal data breach which occurs as a
    result of:
    a) an event which is beyond the control of Hygeia including but not limited to
    government action;
    b) an act or threats of terrorism;
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    c) an act of God (such as, but not limited to fires, explosions, earthquakes,
    drought, tidal waves and floods) which compromises Hygeia’s data
    protection measures;
    d) war, hostilities (whether war be declared or not), invasion, act of foreign
    enemies, mobilisation, requisition, or embargo;
    e) rebellion, revolution, insurrection, or military or usurped power, or civil war
    which compromises Hygeia’s data protection measures;
    f) the transfer of your personal data to a third party on your instructions; and
    g) the use of your personal data by a third party designated by you.
  10. Data Retention
    Hygeia shall retain your Personal Data for as long as is necessary to implement,
    administer and manage your request and contract with Hygeia, or as required to
    comply with legal or regulatory obligations, including under tax and security laws.
  11. How to Contact Us
    For any inquiries you have in relation to this Privacy Policy, please feel free to
    contact our Data Protection Officer at