DATA PROTECTION AND PRIVACY POLICY OF NEM HEALTH LIMITED

1. Introduction

The protection, security, and privacy of your personal information are important to us at NEM Health Limited and to the way we conduct our business in compliance with extant laws on privacy, data protection, and data security. The purpose of this Policy is to outline what information we may collect, how we use and safeguard that information, and with whom we share it.

At NEM Health Limited, we are committed to maintaining the highest standards of integrity in our business. In conducting our business, it is necessary to obtain, handle, process, disclose, transfer, and store information about our clients. We take these activities seriously and seek to provide fair, secure, and appropriate methods that are consistent with both generally accepted privacy ethics and standard business practices when carrying them out.

If you have any comments or questions about NEM Health’s Data Protection and Privacy Policy, please contact our Customer Support Team via customercare@nem-health.com.

2. Personal Identifiable Information (PII)

Through our websites, we will not collect any personal identifiable information about you (e.g., your name, address, telephone number, or email address) unless you voluntarily provide it either by registration on our website, email, inquiry, survey, etc. By using and/or submitting your personal information on our website, you consent to us using your personal information as described below. You also consent to us transferring your personal information where it is done in connection with us providing services to you or where it is necessary for us to fulfil our legal obligations.

By clicking on the “accept” button or by ticking the “accept” box, you are accepting and consenting to the practices, terms, and conditions described in this Policy.

Note that you can withdraw your consent at any time. However, such withdrawal of consent would not affect the lawfulness of processing information based on consent given before its withdrawal.

3. How does NEM Health collect your information

We collect the content, communication, and other information you provide to us when you use any of our products and services. These include when you:

• Fill forms, questionnaires, or surveys;
• Provide credit card details (such as when purchasing products from us);
• Contact us with an inquiry or ask us to provide you with information.
• Register on our website or leave any comments or reviews.
• Attend any of our promotional events.
• Inform us of your marketing preferences, and/or communicate with us via social media websites, third-party apps, or similar technologies.

4. Information that is automatically collected

Regarding each of your visits to our website, office, or the use of our products, we may collect the following information:

• Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type, time zone setting, browser plug-in types and versions, operating system, and platform;
• Information about your use of our website (including date and time), details of transactions you carry out, interaction information, record of any correspondence between us, and any phone number used to call our customer service number;
• Information about your visit(s) from your IP address, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

5. How does NEM Health use your information

We may use your information for any one or more of the following purposes:

• To confirm your identity.
• To maintain your profile.
• To manage your account and keep you updated on all matters that concern your account.
• To provide the services to you that you have requested, including processing transactions;
• To contact you when necessary or appropriate to the services being rendered or provided to you;
• To tailor the content displayed to you;
• To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request from us;
• To provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
• To notify you about changes to our service.
• To ensure that content from our product is presented most effectively for you and your computer.
• For internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
• To improve our product to ensure that content is presented most effectively for you and your device.
• To enable you to participate in interactive features of our service, when you choose to do so;
• To measure or understand the effectiveness of advertising and to deliver relevant advertising to you.
• To make suggestions and recommendations to you and other users of our products about services that may interest you or them.

6. Disclosure of your Personal Information

We will usually not share your personal information with third parties without your consent. Where we need to disclose/transfer your personal information to another country, such a country must have an adequate data protection law. We will seek your express consent where we need to send your personal information to a country without an adequate data protection law.

However, you agree that we have the right to share your personal information with:

• Any member of our group, which means our parent company and subsidiaries as defined under the Companies and Allied Matters Act, 2020,
• Authorized employees of NEM Health Limited are only to resolve issues associated with the use of our products.
• Selected third parties, including business partners, suppliers, or subcontractors for the performance of any contract we enter into with them;
• Advertisers and advertising networks require the data to select and serve relevant adverts to you and others.
• Analytics and search engine providers that assist us in the improvement and optimization of our corporate and product websites.

We may share your personal information without your consent in any of the following situations:

• If we are under a duty to disclose or share your personal information to comply with any legal obligation;
• Where we are requested to provide information by authorized third parties or regulatory/governmental agencies investigating illegal activities;
• If we sell or buy any business or assets;
• If NEM Health Limited or substantially all of its assets are acquired by a third party;
• When you register to attend any of our events, which are sponsored by third parties, we are required to share your personal information with those third parties.

7. Legal Basis for Processing of Personal Information

The legal basis for processing will depend on the purpose for which we have collected and use your personal information. The legal basis for processing is any of the following: 

• Consent: This will apply where you have provided your consent to the processing of your personal information for one or more specific purposes; 

• Performance of a contract: This will apply where processing is necessary for the performance of a contract to which you are a party or to take steps before entering into a contract with you; 

• Protection of vital interests: This is where processing is required for the protection of your vital interests.

 • Compliance with Extant Laws: Where we are subject to a legal obligation and need to use your personal information to ensure compliance.

 • Public Interest: Where processing is necessary for the performance of a task or function carried out in the interest of the public. 

8. Privacy by Design

We will consider privacy implications at the start of new projects or technologies that involve personal data, including the minimization of data collected.

9. Security

We adopt robust technologies and policies to protect your data from unauthorized access, loss, and misuse. Passwords must be kept confidential.

10. Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers. 

11. Where We Store Your Personal Information

Data may be stored inside or outside Nigeria. We take appropriate steps to ensure your data is handled securely and in line with this Policy.

12. Retention of Information

Data is retained only as long as necessary for legal or operational reasons, unless longer retention is required by law.

13. Your Rights as a Data Subject

The law gives you certain rights in respect of the information we hold about you. Below is a highlight of some of those rights. It is, however, not a complete, exhaustive statement of your rights in respect of your personal information. 

• Right to consent to this Privacy Policy and to withdraw your consent at any time. 

• Right to a copy of the personal data we hold about you, as well as the information about what we do with it, who we share it with, and how long we hold it for. Charges may apply for excessive requests.

• The right to freely transfer your data received from us

• Right to have the information we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose.

• Right to the deletion of the information that we hold about you. 

• Right to lodge a complaint about the handling of your personal information with the Nigeria Data Protection Commission (hereinafter referred to as NDPC). 

• Right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your personal information to any third party for such purposes. 

Note: Where we do not act on your request to exercise any of your rights, we shall inform you within one month of the receipt of your request of the reasons for not taking action and on the possibility of complaining to NDPC. NDPC’s website (https://ndpc.gov.ng/) has a wealth of useful information in respect of your rights over your personal information. If you wish to exercise your rights, you may contact our office at info@nem-health.com.

14. Changes to our Policy

Any changes or amendments we make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please visit this page frequently to see any updates or changes to this Policy.

15. Data Breach Management

In the event of a data breach, NEM Health Limited has established a structured response to mitigate risks and ensure compliance with legal and regulatory requirements. The key components of the Data Breach Management Policy include

 • Identification and Reporting: Employees must promptly report any suspected data breach to the Data Protection Officer. 

• Investigation and Containment: The IT and Compliance teams will assess the breach's impact and take necessary steps to contain it.

 • Notification: Affected individuals and regulatory authorities will be informed immediately and the NDPC will be notified within 72 hours of such breach. 

• Remediation and Review: After resolving the incident, a thorough review will be conducted to prevent future occurrences. 

16. Data Subject Request Procedure

Individuals have the right to access, correct, delete, or restrict the processing of their data. NEM Health Limited ensures a transparent and efficient process for handling data subject requests:

•  Submission: Data subjects can submit their requests through a designated online portal or email.
• Verification: The requestor’s identity will be verified to prevent unauthorized access.
• Processing: Requests will be reviewed and fulfilled within the statutory timeframe.
• Response: Data subjects will receive a formal response confirming the action taken or providing justification if the request is denied. 

17. Governing Law

The Nigeria Data Protection Act, 2023, governs this Data Protection and Privacy Policy. All procedures, practices, and principles outlined herein comply with NEM HEALTH LIMITED – DATA PROTECTION AND PRIVACY POLICY, the obligations and responsibilities imposed under this Act to ensure your data is processed lawfully, fairly, and transparently.

18. Contact

Email: customercare@nem-health.com

Head Office: 199, Ikorodu Road, Obanikoro, Lagos, Nigeria

Phone numbers: 02013300150 | 02013300151 | 02013300152

💬 WhatsApp: 08077284810