PRIVACY POLICY

Privacy Policy

Effective date: September 2019

Whispa Health Limited (“us”, “we”, or “our”) operates the mobile application called Whispa (“whispa health” or “the app” hereinafter referred to as the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

By using the Service, you agree to the collection and use of information in accordance with this policy.

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Definitions

Service: Service is the mobile application- Whispa created and owned by Whispa Health Limited

Personal Data: Personal Data means data about a living individual who can be identified from those data(or from those and other information either in our possession or likely to come into our possession).

Health information: This includes medical history or any type of health information about the user that may come into our possession

Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies: Cookies are small files stored on your device (computer or mobile device).

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data: While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally, identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Address, State, Province, ZIP/Postal code, City

• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Health Information: This includes:

• Self-Reported Health Information – We collect the information that you enter while using the service, such as information regarding your health and/or medical condition and related behaviours.

• Provider-and-Payer-Reported Health-Related Information – We collect information about you that is submitted with your permission by your authorized healthcare provider or other third party while using the Service, such as information about your health and/or medical condition, including information that is protected under HIPAA.

Usage Data: When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data (“Usage Data”).

Location Data: We may use and store information about your location if you give us permission to do so (“Location

Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data: When accessing our service through the web, we use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies may also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.

• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

• Security Cookies. We use Security Cookies for security purposes.

Analytics

Whispa Health may collect and use your device’s unique identifier for analytics purposes or to store

your user preferences. Whispa Health may use Google Analytics or other third-party services to

monitor and analyze your user behavior.

• Google Analytics is a web analysis service provided by Google, Inc. (“Google”). Google utilizes

the Data collected to track and examine the use of the Service, to prepare reports on its activities and to share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

 

Use of Data

Whispa Health Limited uses the collected data for various purposes:

• To provide and maintain our Service

• To notify you about changes to our Service

• To allow you to participate in interactive features of our Service whenever you choose

• To personalize the Service.

• To provide customer support

• To gather analysis or valuable information so that we can improve our Service

• To monitor the usage of our Service

• To detect, prevent and address technical issues

• To provide you with news, special offers and general information about other goods, services

and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

• To send you push notifications or desktop notifications according to their user settings

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside Nigeria and choose to provide information to us, please note that we transfer the data, including Personal Data, to Nigeria and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Whispa Health Limited will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Legal Requirements: Whispa Health Limited may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation

• To protect and defend the rights or property of Whispa Health Limited

• To prevent or investigate possible wrongdoing in connection with the Service

• To protect the personal safety of users of the Service or the public

• To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.

These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Flutterwave

Their Privacy Policy can be viewed at https://paystack.com/terms

• Apple Store In-App Payments

Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

• Google Play In-App Payments

Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

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 take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We may let you know via email and/or a prominent notice on our service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: info@whispahealth.com