Privacy Policy

INTRODUCTION

Welcome to the International Health Management Services Limited (IHMS HMO) (the” Firm”, “We”, “Us”, “Our”) Privacy Notice. This privacy notice was updated on 25th August 2022 in accordance with Nigeria Data Protection Regulation (NDPR) 2019. This Privacy Notice describes who we are, how we collect, use, store and share your personal information and the rights available to you. This Privacy Notice applies to anyone who accesses our main website @https://ihmsnigeria.com/ engages in our services or participates in our recruitment exercises or events. Please read the entire Privacy Notice to understand how we process your personal information and the rights available.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA] 6. [INTERNATIONAL TRANSFERS]
6. [DATA SECURITY]
7. [DATA RETENTION]
8. [PRINCIPLES OF DATA PROTECTION]
9. [YOUR LEGAL RIGHTS]
10. [CONTACT DETAILS]

1. Important information and who we are
IHMS HMO (the “Firm”, “We”, “Us”, and “Our) is a National Health Maintenance Organisation (HMO) that specialises in Health Insurance Services, TPA, and Health Care. We are located at 2 Joseph Street, Off Broad Street, Lagos Island, Lagos. For more information about IHMS HMO, please visit https://ihmsnigeria.com
You have the right to complain to the Nigeria Data Protection Bureau (NDPB), the Regulator for data protection issues (https://ndpb.gov.ng/).
However, we would appreciate the chance to address your concerns before you approach the NDPB, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking or enabling those links may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The information we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction This includes personal information collected during contractual or client relationships between you or your organisation and Medismarts.
• Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Physical Access Personal Data includes the personal information we collect about you when you visit our physical office.
Information About Other People- If you provide information to us about any person other than yourself, your employees, counter-parties, your advisers or your suppliers, you must ensure that they understand how their information will be used and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it
We may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) but we do not collect any information about criminal convictions and offences.

If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?
We use different methods to collect data from and about you, and they include:
Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• Direct interactions. You may give us your personal data by filling out forms or corresponding with us by post, phone, email, or otherwise.
• Automated technologies or interactions. We collect personal data as you interact with our website. This includes personal data about your equipment, browsing actions, and patterns. We collect this personal data by using server logs and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources that are available to us.

4. Purpose/Lawful bases for using your personal data
In the table below, we have described all the ways we plan to use your personal data, the legal bases we rely on, the purpose of processing such personal data and the legal rights available to you. We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your personal data. Kindly contact us if you need further details or clarity about the legal ground we rely on to process your personal data, which is more than one ground, as set out in the table below.

Type of data		Lawful basis for processing, including basis of legitimate interest	Your Legal Rights
(a)Identity	To register you as a new customer	Performance of a contract with you
(b) Contact



(a) Identity	To process and deliver your order including:	(a) Performance of a contract with you
(b) Contact	(a) Manage payments, fees and charges	(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Financial	(b) Collect and recover money owed to us
(d) Transaction
(e) Marketing and Communications

(a) Identity	To manage our relationship with you which will include:	(a) Performance of a contract with you
(b) Contact	(a) Notifying you about changes to our terms or privacy policy	(b) Necessary to comply with a legal obligation
(c) Profile	(b) Asking you to leave a review or take a survey	(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(d) Marketing and Communications


(a) Identity	To enable you to partake in a prize draw, competition or complete a survey	(a) Performance of a contract with you
(b) Contact		(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
(c) Profile
(d) Usage
(e) Marketing and Communications


Identity and contact data	To process employment applications	Necessary for our legitimate interest to recruit employees
		Performance of contract





(a) Identity	To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Contact		(b) Necessary to comply with a legal obligation
(c) Technical




(a) Identity	To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Identity data	To exercise or defend our legal rights or to comply with court orders	Necessary to comply with legal obligation
Contact data		Necessary for our legitimate interest to defend or exercise our legal rights.
Transaction data




Identity and contact data	To fulfil legal requirements such as maintaining records, taxes and other compliance checks	Necessary to comply with legal obligation






(a) Technical	To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
(b) Usage





(a) Identity	To make suggestions and recommendations to you about goods or services that may be of interest to you	Necessary for our legitimate
(b) Contact
(c) Technical		products/services and grow our business)
(d) Usage
(e) Profile
(f) Marketing and Communications

Promotional offers from us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services, and offers may be relevant to you; we call this marketing.

You will receive marketing communications if you have requested information from us or purchased goods or services from us and have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose
We will only process your personal data for the particular purposes for which we collected it, unless we have reason to use it for another purpose. Please note that where this is the case and the further purpose is not compatible with the original purpose, we will notify you and rely on appropriate lawful basis before using it for such purpose. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.

• Our subsidiary undertaking or partners
• Courts, law enforcement authorities, regulators or governmental bodies
• Financial institution
• Lawyers for the purpose of establishing, exercising or defending legal claims
• Business partners or contractors
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers
We may transfer your personal data to foreign countries while rendering our services or operations. However, whenever we transfer your personal data outside Nigeria to countries deemed not to have adequate data protection law by NDPR (see Article 2.11 NDPR and Paragraph

7.0 Implementation Framework), we will comply with the proper safeguards or exceptions created by the law. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Nigeria

7. Data security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data according to our instructions and are subject to confidentiality duties.
We have implemented procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes they were collected for, including legal or regulatory purposes, tax, and accounting or reporting requirements and where we are required to assert our or defend against legal claims, pending the final adjudication of the claim. In some circumstances, we will anonymise your personal data so that it can no longer be associated with you for research or statistical purposes. In this case, we may use this information indefinitely without further notice. Please contact us to learn more about our retention periods, which are established in our retention policy.

9. Principle of Data Protection
We are obligated to comply with data protection principles whenever we process your personal information and to inform you about these principles.

These principles include:
• We must inform you about the personal information we have about you and the lawful basis for processing it, and we must use it in a way you reasonably expect. (Principle of Transparency, Lawfulness and Fairness)
• We should not use your personal information for more than one reason if not compatible with the reason we collected it except we have informed you and relied on an appropriate lawful basis (Principle of purpose limitation)
• We should only collect personal information about you that is necessary to meet our purpose and nothing more (Principle of data minimisation)
• We should only use your correct personal information in the course of our processing activities (Principles of data accuracy)
• We should not store or keep your personal information in our custody beyond the period necessary to fulfil the purpose for which it is collected (Principle of storage limitation)
• We should ensure that your personal information about you in our custody is protected from unauthorised use, alteration or corruption. (Principle of integrity and confidentiality)
• We should take measures to ensure and demonstrate compliance with these principles (Principle of accountability).

10. Your legal rights
You have certain rights under the law, which we respect and comply with, and which you can exercise anytime. However, these rights are not absolute and only apply in certain circumstances. You may check the table above or contact us to find out more about when these rights apply.
• right to access to your personal data
• right to request correction of your personal data free of charge
• right to request the erasure of your personal data
• right to object to the processing of your personal data
• right to request restriction of processing of your personal data
• right to request transfer of your personal data
• right to withdraw consent that we may need from you may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This security measure ensures that personal data is not disclosed to anyone with no right to receive it. We may also contact you to ask you for further information concerning your request to speed up our response.

11. Contact Details
Please address questions, comments and requests regarding this Notice to Privacy to legal@ihmsnigeria.com, aogunsolaihmsnigeria.com or call 08085860070 or send a letter to our physical office @ IHMS, 2 Joseph Street, Off Broad Street, Lagos Island, Lagos, Nigeria.