AMANI HEALTH PRIVACY NOTICE

Last Revised Date: April 2024

Introduction

Amani Health Teletherapy Service (“we” “our”, or “us”) is a technology company with the mission of providing our clients (“users”, “your” or “you”) with access to professional therapy sessions(“Services”).

By accessing or using our Services, or otherwise assenting to this Privacy Notice (“Notice”), you signify that you have read, understood, and agreed to our collection, storage, use and disclosure of your personal information as described in this Notice and our Terms of Use.

1. Policy Overview

At Amani Health, we take privacy and security very seriously, and to demonstrate our commitment to privacy and security, we have developed this Notice, to explain how we may collect, retain, process, share and transfer your Information.
We recommend that you read this Notice carefully to understand your rights and our duties towards managing your information in addition to our Terms of Use, which is incorporated into this Agreement.

2. Version Control

We may in our sole and absolute discretion, change or revise this Notice, and any other policy or agreements which are referenced or incorporated under it. Such changes or revision shall be effective immediately upon posting it on www.amanihealth.app or web application. We will notify you of such changes or revision by indicating the “Last Revised Date”. Your continued use of our Services after such change or revision shall constitute your acceptance of the Notice. If you do not agree to the Notice as at the Last Revised Date, do not use or continue to use our Services.

3. Applicability and Scope

This Notice applies to your information, when you visit www.amanihealth.app or use our Services through our web application, where applicable.

4. Consent and authorisation

By using our Services, you consent to the recording, storage and disclosure of such information you send or receive for the purposes of using our Services.
We may, but have no obligation to monitor, record and store information you provide to us as well as the information we collect about you, in order to protect your safety or the safety of other users, and to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property.

5. Category of Information we collect

For the purpose of this Notice, the nature of information we collect is personal information. Personal information are unique information or aggregated data, which when processed with other information can identify you as a human being;
The nature of personal information we collect are those which are necessary for the purpose of providing our Services to you and they include:
Individual Information: this may include names or alias, physical address, work address, phone number, email address, IP address, date of birth, gender, social media address, photo identification, Identity card, selfie or video authorization, images of your face on your identification document, facial identifiers and other additional information you may provide or additional information, we may request you to provide;
Device Information: this may include information about the hardware model, operating system and version of your device, as well as the unique identifiers, browser type and version, the presence of any device, browser add-ons, the times you access our Services, the locations from where you access our Services, the page you access before navigating to our Services, your stored contacts and mobile network information of your device, when you access www.amanihealth.app or use our Services through our web application, where applicable;
Location Information: we may receive information from you that helps approximate your location, such as using an IP address received from your browser to determine an approximate location. We may also collect location information from devices in accordance with the consent process provided by your device;
Information collected using our Services: we collect information about how you use our Service, your actions on and your communications with us through www.amanihealth.app or web application, where applicable.

6. How we collect your information

We automatically collect public and non-public information about you when you visit www.amanihealth.app or use our web application, where applicable, or communicate with us through our customer support channels or when you apply or sign up to use any of our Services through a third party platform or read our emails, or through third party service providers and other sources, or through online research on social media and websites which may not be publicly available;
We typically collect this information through variety of tracking technologies including cookies, flash objects, web beacons, file information and similar technologies (“tracking technologies”);
We may use the data collected through tracking technologies to:
Remember information so that you will not have to re-enter it during your visit or the next time you visit our website or web application;
Provide custom, personalised content and information, including targeted content and advertising; 6.3.3. Identify you across multiple devices;
Provide and monitor the effectiveness of our Services;
Monitor aggregate metrics such as total number of visitors, traffic, usage and demographic patterns on our Services;
Diagnose or fix technology problems and otherwise to plan for and enhance our Services;
We may use one or more third party analytics services to evaluate your use of our Services, by compiling reports on your activities on www.amanihealth.app our web application, where applicable and analysing performance metrics. By assessing and using our Services, you consent to the processing of your data by these analytics providers in the manner and for the purposes set out in this Notice.

7. Purposes of collection and use of your information

We use the information we collect or receive to operate; improve and protect the Services we provide and to develop new Services;
More specifically, we collect and use your information to:
Develop, improve, enhance, modify add to and further develop our Services;
To provide the Services, perform obligations under our agreements and carry out related business functions;
Comply with legal obligations and regulations applicable to our Services;
Conduct record keeping and otherwise manage the business;
Verify you, your identity, that the data you provide is credible;
Protect you, our website, web application where applicable and Services from malicious activity and other privacy and security risks;
Provide customer support to you, including to help respond to your inquiries related to our Services or our website and web application, where applicable;
Send you technical notices, updates, security alerts, support, and administrative messages;
Investigate any misuse of our Services or www.amanihealth.app or web application, where applicable, including criminal activity or other unauthorised access to our Services;
Process and facilitate payment for Services facilitated by us;
Deal with disputes and complaints;
For any other purpose with your consent;
We may use raw or aggregated and anonymised data for the purposes provided in this Notice. When a new user creates an account with us, we programmatically compare that user’s data against others in our database to help detect potential cases of identity theft.

8. Sharing your Information

We take your privacy seriously and as such we do not sell or rent your personal information to anyone and do not use your data for commercial purposes other than identity verification and for the purposes covered under this Notice and other documents referenced under it.
We may share your information in the instances described below:
With third parties at your request;
For our everyday business purposes, particularly in relation to our Services under this Notice;
With other companies that provide services to us, such as data analytics, identity verification service providers;
To information technology providers or other service providers around the world that act under our instructions regarding the processing of some of your data (“Vendors”). These Vendors will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the information shared with them and to process information only as instructed by us;
To support our compliance and corporate governance functions; and
With your consent or direction or as otherwise required by law.
Subject to applicable laws, we may disclose data if required or permitted by applicable laws or regulations of Nigeria, including the laws and regulations of other countries in the good faith and belief that such action is necessary to:
Comply with a legal obligation or in response to a request from a law enforcement or other public authorities wherever we may do business
Protect and defend our rights
Act in urgent circumstances to protect the personal safety of our users, our website, web application, where applicable or Services, as well as our employees or contractors;
Protect against any legal liability.

9. Protection of your information

Amani Health takes commercially reasonable measures to help in the protection of your information from loss, theft, misuse and unauthorised access, disclosures, alteration, and destruction. We also implement policies which are designed to protect the confidentiality and security of your nonpublic personal information;
Unless otherwise specified in this Notice, we limit access to your information to employees that have a business reason to know such information and further implement security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with our policies.

10. Control over your information

You may update your profile information, such as your account name, social media handles, social media access hours, where applicable and may change some of your data sharing preferences on your settings page;
Where applicable, you may control our web application’s access to your device information through the settings app on your device. For instance, you can withdraw permission for our web application to access your saved contacts, location, photo stream and camera;
You can stop receiving promotional email communications from us, by clicking on the “unsubscribe” link provided in such emails. We make every effort to promptly process all unsubscribe requests. You may not opt out of service related communications such as changes to features of our Services, technical and security notices;
If you would prefer not to accept cookies, most browsers will allow you to change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it or not, disable existing cookies, or to set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Services may not work properly;
If you have any questions about reviewing, modifying, or deleting your information, please contact us directly at contactus@amanihealth.app we may not be able to modify or delete your information in all circumstances.

11. Data Retention and Protection

Your information collected through our Services may be stored and processed in Nigeria or any other country in which we maintain facilities, or in which you utilise our Services;
Please note that we may transfer information, including personal information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and you acknowledge such transfer or information to such other country in which Amani Health or its parents, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Notice;
We retain your information to fulfil our legal or regulatory obligations and for our business purposes. We may retain your information for longer periods than required by law if it is in our legitimate business interests and it is not prohibited by law;
If you stop using our Services and close your account with us, we reserve our ability to retain and access the data as provided in this Notice. We will continue to use and disclose such data in accordance with this Notice;
All data or information are stored in encrypted formats in Amani Health’s database.

12. Surveys

We may request that you complete a survey on the Services we provide to you, for us to better understand your perception of our Services and to further improve on them. If you choose to participate in any of such surveys, we may collect demographic information about you, such as your age, marital status, ethnicity, profession, or other sensitive information. We may also collect information about the way you utilise our Services and your experiences while using it. By participating in such a survey, you consent to our collection and use of the information you provide in accordance with this Notice.

13. Links to third party websites

Our Services, www.amanihealth.app or web application, where applicable, may contain links to third party websites of our partners or contractors. While we take appropriate care when publishing links to any third-party service, if you follow a link to any website, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

14. Governing Law

This Notice is made pursuant to the Nigeria Data Protection Regulation 2019 as well as all other laws, regulations, or international conventions which Amani Health in providing its Services and within the country of its operations is subject to. Where any provision of this Notice is deemed inconsistent with such law, regulation or convention, such provision shall be subject to the overriding law, regulation, or convention.

15. How to contact us

If you have any questions about this Notice or our website as well as our web application, please contact us at contactus@amanihealth.app.

PRIVACY POLICY

About Your Privacy and This Privacy Policy

Your privacy is extremely important to us. We are constantly putting a great deal of thought, effort, tools, resources, and procedures in place in order to protect and safeguard the confidentiality and privacy of information entrusted to us. Amani 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," and it contains details on issues related to your privacy when using our services. The Privacy Policy is part of our Terms and Conditions and has the same meaning as in our Terms and Conditions document. This Privacy Policy applies to visitors to the public websites owned and operated by Amani Health and to the Health Professionals that provide the therapy Services. It is intended to inform you of our policies, procedures, and practices regarding the collection, use and disclosure of any information that you provide through the Platform. 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. By accessing and using our Platform or providing the therapy Services, as applicable, you affirm that you have read the Terms and Conditions and the Privacy Policy and that you understand, agree to and acknowledge all the terms contained in both of them. If you do not agree to be bound to this Privacy Policy, you should stop using the platform immediately.

What Information We Collect, Use, and Disclosure

In order for us to operate the Platform effectively and to enable you to use the Website, including having access to therapy sessions with a therapist, we may collect, use, and store personally identifiable information if you choose to provide it in the course of business. We also disclose and collect certain information to third parties if you choose to register or login to the Amani 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.)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. The information we collect is received directly or indirectly from you and generated in the course of your use of the Platform. The data we collect is not used for marketing or any other purposes unless we obtain your permission except as specified in this Privacy Policy or unless otherwise required or permitted by law or professional standards. By registering and/or submitting personal information to Amani Health, you are also acknowledging that Amani Health uses the information in the ways detailed in this Privacy Policy.

The personally identifiable information that we may collect include but is not limited to:

Basic visitor information: such as your name (including name prefix or title), the company you work for and your title or position. The website collects, uses, and stores data.

Registration/Onboarding information: such as your contact address, email address and phone number(s), billing and payment information, user’s self-reported name or nickname, age, and emergency contact information. In addition, responses to the questionnaire provided by users, pages viewed by the user, whether the user clicks the "Get started" link or any such similar link to begin completing the questionnaire, and whether the user responds to any of the questionnaire prompts that help assign/match each user to Therapists.

Technical data: such as information from your visits to our website or in relation to materials and communications we send to you electronically, including the particular pages visited or viewed by the user, the amount of time the user spent on the website or application, website errors experienced by the user, visits to "FAQ" page, and information about the browser or device used to access the website, such as the user’s mobile device ID and IP address. These practices apply to users who visit pages as prospective new customers as well as those who visit pages as prospective Therapists.

Therapy Data: Information you provide to us for the purposes of using our services, information related to the Therapist’s Services or your need for a Therapist, and any information exchanged between you and your Therapist such as whether a live session has been scheduled by the user, whether a Therapists or user joins a scheduled session, when a therapy session began and ended, and whether a therapy session was cancelled or rescheduled.

Log In Data: Personal information provided to us by or on behalf of our users or generated by using the course of providing services to them. Activity conducted during that login such as when a user logs in, the number of messages received or sent through Amani’s website during that login, and whether a user has been assigned, started, or completed a therapy goal ("Login Data"). Personal information provided to us by third parties.

Therapists Data: In order to identify, verify, re-verify run checks, and pay Therapists, Amani Health collects, uses, and stores certain data from Therapists. This data includes information such as the name, bank account information, governmental identification numbers, e-mail address, phone number, physical address, education, and job history.

Transaction Data: such as whether a user completed payment for Amani Health services, signed up for Amani Health using a trial offer, cancelled or otherwise ended a trial.

Protecting this information is important to us. Other than in the ways detailed in this Privacy Policy, we will never use or disclose any information unless you request or approve us to do so.

Purposes for Which Information Is Used

We may use the information we collect for one or more of the following purposes as permitted by law in Nigeria:

To contact or provide you with information, alerts and suggestions that are related to the Platform;
To verify your identity;
To complete an activity you requested, such as register on the Platform or obtain more information;
To reach out to you, either ourselves or using the appropriate authorities, if we have a 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;
To create your account on our Platform and let you log in to your account and use the Platform;
To manage your account, provide you with customer support, and ensure you are receiving quality service;
For billing and transaction processing purposes;
To match users with therapists and facilitate the therapist Services;
To provide, support, personalise, and develop our Platform and the therapists’ Services;
To supervise, administer and monitor the Platform;
To measure and improve the quality, effectiveness, and delivery of our services;
To personalise the website experience and to deliver content and product and service offerings relevant to individual interests, including targeted offers and ads;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
To comply with applicable local and/or state and federal laws, including, but not limited to laws related to protecting client and public health and safety;
To allow therapists to comply with the licensure, legal and quality requirements in their jurisdictions;
Any other purpose with your consent.

Disclosure to Third Parties

Information About you is not disclosed to non-affiliated 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 for one or more of the following purposes:

1. For business purposes: Only as necessary for facilitating the therapy Services, we may share a user’s information with a therapist and a therapist’s information with a user. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms;
2. With your direction or consent: We may share your information with third parties if you request or direct us to do so;
3. With affiliates within our corporate group: We may share your information with any subsidiaries or parent companies within our corporate group;
4. For advertising: If you are opt-in to the use of targeting cookies and web beacons, information regarding your activity on our websites, excluding activity when you are logged in and have started therapy, may be disclosed to our advertising partners to optimise marketing. We do not share with any advertising platform private information like member names, email addresses, phone numbers, diagnosis, session data, journal entries, messages, worksheets, or any other type of communication you have with your therapist;
5. Compliance with law: We may share your information with a court, regulatory bodies, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder;
6. Audits: We may share your information in connection with an asset sale, merger, bankruptcy, or other business transaction;
7. For other business reasons: We may share your information to enforce any applicable Terms and Conditions and Terms of Use, and to ensure the safety and security of the Platform and our users;
8. Our service providers: Amani Health works with reputable strategic partners, service providers or agencies so they can process your personal information on our behalf.

Amani 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.

In addition, Amani 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. Note that if you make any information publicly available on the Platform, anyone may see and use such information.

We will rely on one or more of the following processing conditions and grounds when we collect your personal information:

The performance of a contract, is when the processing of your personal information is necessary to perform our obligations under a contract or for us to take steps at your request;
A Legal obligation, 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 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 [contactus@amanihealth.app](contactus@amanihealth.app);
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.

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 keeping a record of your preferences to tailor your experiences while on our site or to help us analyse our website traffic. 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 a 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. A web beacon is a tiny image, sometimes an invisible image or embedded code, placed on a web page or email that can report your visit or use and is typically used by third parties in monitoring the activity of a user for web analytics, advertising optimization or page tagging.

Like many websites, we use "cookies" and "web beacons" to collect information. You can change your browser's settings so it will stop accepting cookies and web beacons (often found in your browser's Tools or Preferences menu) or prompt/notify you before accepting a cookie or web beacon. 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 website's features.

We may use third-party cookies or web beacons for the purposes of web analytics, attribution, and error management. 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 using Vendor services, but this is for the purpose of identifying the number of unique visitors to our websites and the 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.

BY NAVIGATING ON OUR WEBSITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER ON AN INTERNET-ENABLED DEVICE.

Social media and General Information Tools

We may use several publicly available tools and information exchange resources, such as (but not limited to) a blog, Google, Facebook, Twitter, and others to enable sharing. Any information you provide or share while using Social media and General Information Tools may be read, accessed, and collected by that site and users of that site according to their Privacy Policy. We do not have control over or responsibility for those companies or their use of your information.

In addition, Amani 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 Amani 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.

Amani Health may interact with registered users of various social media platforms, including Facebook, Twitter, LinkedIn, 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 to better understand your rights and obligations regarding such content.

Phishing

Online identity theft and account hacking, including the practice currently known as "phishing", are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

Location-based tools

Amani 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.

Data Security and Information

Using any Internet-based service carries inherent security risks, despite our best efforts, security against all threats can therefore not be 100% guaranteed. Amani Health systems, infrastructure, encryption technology, operation and processes are all designed, built, and maintained to protect personal data from unauthorised loss or access, misuse, modification, alteration, destruction, or disclosure under our control. Where we have provided you (or where you have chosen) a password that grants you access to specific areas on our site, you are responsible for keeping this password confidential. We request that you do not share your password or other authentication details (e.g. generated codes) with anyone.

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.

Children's Privacy

We understand the importance of protecting children’s privacy, especially as they are our primary audience, and we are committed to protecting their privacy. If you are aware of any concern that we should know of in this regard, please let us know by contacting us at [contactus@amanihealth.app](contactus@amanihealth.app) and we will take immediate actions as required and permitted by the law.

Links to other websites

Please be aware that our website 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 their privacy policies. 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, authorisation, 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

Amani Health may modify this Privacy Policy from time to time at our discretion 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. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform.

Contact us

If you have any questions, comments or concerns about this Privacy Policy or questions, comments, or requests about our administration of your personal information, please contact us at [contactus@amanihealth.app](contactus@amanihealth.app)