Introduction

Health Strategy and Delivery Foundation (and, where applicable, its subsidiaries and related entities) (hereinafter called “HSDF”/ “We”/ “Our”) is a non-profit firm established to improve the quality of decision-making and execution to positively impact the transformation of the Nigerian and African health and social sectors. We treat the personal information of users (hereinafter referred to as “Users”/ “You”/ “Your” “Yourself”) of the HSDF Website “www.hsdf.org.ng” and its other digital platforms (hereinafter called the “Site”) as private and confidential.

This Privacy Policy statement (“Privacy Policy”) governs the use of our Website whether accessed directly, via mobile software, or through a third-party application or service. This Privacy Policy sets out our policies and procedures regarding the collection, use and disclosure of information on our website. Other than as set forth herein, we will not provide your personally identifiable information (“Personal Information”) to third parties without your specific permission. We respect your privacy and are committed to protecting the Personal Information you may provide us through our Website and other digital platforms.

Your Acceptance of These Terms

You can visit our website and continue to access most of its content without telling us who you are or revealing any personal information about yourself. Once you give us your personal information, you are not anonymous to us. Any personal data we collect from users is kept on a secure server and protected by the latest software and hardware components.

By continuing to access this website, you acknowledge that you have read and agree to be bound by the terms of this privacy policy and that you consent to have your data transferred to, and processed in, the federal republic of Nigeria. If you do not accept these terms, you may wish to immediately stop accessing our website.

The Information We Collect

Our Website typically collects two kinds of information about you:

Personal Information or Personal Data

We may receive and store any information you enter on our website or provide it to us in any way. Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your name, mail address, phone number, etc. As a general policy, we do not automatically collect your personally identifiable information when you visit our Website. In certain circumstances, we may request, allow or otherwise provide you with an opportunity to submit your personally identifiable information in connection with a feature, program, promotion or some other aspect of our Website. For instance, you may:

(a) provide your name, mail address, email address, phone number, etc. when registering with our Website, creating a profile or submitting your resume;

(b) provide certain demographic information about you (e.g., age, gender, education, etc.) when participating in a survey or poll; or

(c) post a general comment and/or recommendation on our Website.

Whether or not you provide this information is your choice; however, in many instances, this type of information is required to participate in a particular activity, realize a benefit we may offer or gain access to certain content on our Website.

Non-Personal Information or Usage Data

Our definition of non-personal information is any information that does not personally identify you. Non-personal information can include certain personally identifiable information that has been de-identified; that is, information that has been rendered anonymous. We obtain non-personal information about you from information that you provide us, either separately or together with your personally identifiable information. We also automatically collect certain non-personal information from you when you access our Website. This information can include, among other things, IP addresses, the type of browser you are using (e.g., Internet Explorer, Firefox, Safari, etc.), the third-party website from which your visit originated, the operating system you are using (e.g., Windows 10, Mac OS, Linux, etc.), the domain name of your Internet service provider (e.g., MainOne, VDT, FiberOne, Swift, MTN, 9mobile, Cobranet, etc.), the search terms you use on our Website, the specific web pages you visit, and the duration of your visits.

If you access our website via a mobile device, we may collect or receive information that uniquely identifies your device (unique device identifiers or UDID, MAC address and IP Address).

The Data We Do Not Collect

 At HSDF, we do not ask for or gather sensitive personal data that could lead to significant harm or risk to you, such as financial losses, privacy breaches, or unauthorized access to financial accounts. We highly advise you against sending this information to us through any of our channels or sharing it with anyone directly employed or affiliated with HSDF. This data includes, but is not limited to:

• Passwords
• Personal Identification Numbers (PINs)
• Credit/Debit Card Information
• Tokens
• Authentication Codes
• Other Private Financial Information

We are committed to maintaining the confidentiality of your data and ensuring that sensitive personal information is not collected or stored in our systems.

What We Do With Your Personal Data

We won’t sell or rent your Personal Information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other sources and use it to improve and personalize our services, content, and advertising. We may also use your Personal Information to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements with you, including this Privacy Policy, comply with applicable law, and cooperate with law enforcement activities.

We share the information we receive or collect only as provided herein or with your consent, to our subsidiaries or other affiliated entities.

Personal Information

The personally identifiable information you submit to us is generally used to carry out your requests, respond to your inquiries, better serve you, or in other ways directly associated with the circumstances in which you provided the information. We may also use this information to later contact you for a variety of reasons, such as completing surveys, providing you promotional information for our services or those of our subsidiaries or other affiliated entities (“Affiliated Entities”), or communicating with you about the content or other information you have posted or shared with us via our Website. You may opt-out from receiving future promotional information from us or our Affiliated Entities, or direct that we do not share your information with any Affiliated Entities, as set forth below.

In certain instances, we may also share your personally identifiable information with our third-party vendors performing functions on our behalf (or on behalf of our affiliated entities) – e.g., vendors that process or help with data analysis, IT systems implementation vendors, solution providers etc. our vendors agree to use this information, and we share information with them, only to carry out our requests. In addition, we may share your Personally Information with participating sponsors or donors of a program you enter via our Website. Further, we may share your personally identifiable information with third parties such as our co-promotional partners and others with whom we have other relationships. Except as provided in this Privacy Policy, or as set forth, when you submit the information, your personally identifiable information will not be shared or sold to any third parties without your prior approval.

We may release Personal Information when we believe in good faith that such release is necessary to comply with the law; enforce or apply our Policy; or protect the rights, property, or safety of HSDF, our employees, our users, or third-party service providers engaged with the Website or our business. This includes, without limitation, exchanging information with other companies and organizations for fraud detection/prevention.

You will be notified when your personal information may be shared with third parties under circumstances other than those listed above.

Non-Personal Information

We use non-personal information in a variety of ways, including to help analyze site traffic, understand user needs and trends, carry out targeted promotional activities, and improve our services. We may use your non-personal information by itself or aggregate it with information we have obtained from others. We may share your non-personal information with our affiliated entities and third parties to achieve these objectives and others. This aggregate information is anonymous information that does not personally identify you.

Other Uses & Information

IP Addresses

An IP address is a number that is automatically assigned to your computer whenever you are surfing the Internet. Web servers (computers that “serve up” web pages) automatically identify your computer by its IP address. When visitors request pages from our Website, our servers typically log their IP addresses. We collect IP addresses for purposes of system administration, report non-personal aggregate information to others, and track the use of our Website. IP addresses are considered non-personal information and may also be shared as provided above. It is not our practice to link IP addresses to anything personally identifiable; that is, the visitor’s session will be logged, but the visitor remains anonymous to us. However, we reserve the right to use IP addresses to identify a visitor when we feel it is necessary to enforce compliance with our Website rules or to (a) fulfil a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) in an emergency to protect the health and safety of our Website’s users or the general public.

Email Communications

If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we strongly kick against providing non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. Aside from responding to an email received from you, it is not our standard practice to send you an email unless you request a particular service or sign up for a feature that involves email communication, or in case of sending you information about our other products and services. In certain instances, we may provide you with the option to set your preferences for receiving email communications from us; that is, agree to some communications but not others. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below.

Transfer of Assets

As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the personally identifiable information and non-personal information we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Other Usage Rights

Notwithstanding anything herein to the contrary, we reserve the right to disclose any personally identifiable or non-personal information about you if we are required to do so by law, concerning copyright and other intellectual property infringement claims, or if we believe that such action is necessary to (a) fulfil a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) in an emergency to protect the health and safety of our Website’s users or the general public.

How We Collect Your Data

you share your personal data with us when you:

• Submit a form using the contact us or career pages of our website
• Register for or take part in any HSDF events
• Complete online forms
• Take part in any of our surveys
• Contact us using any online/offline channels including social media platforms, paper-based forms etc.

Where We Store Your Personal Data

All personal data that are kept and processed within HSDF will be transferred and stored in our Tier 4 cloud storage facilities within the whitelisted countries list of NDPR. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy.

Cookies and Preference-Based Advertising

Cookies and Pixel tags

We automatically receive and store certain types of non-personally identifiable information whenever you interact with us. For example, like many websites, we use “cookies”, “log data”, or “pixel tags” and other identifiers to receive and store certain types of information such as your IP address, pages you requested, and history when your web browser accesses our Website. The Website may automatically collect usage information, such as the numbers and frequency of visitors to our Websites and their components.

• “Cookies” are small files that we transfer to your computer’s hard drive or your web browser memory to enable our systems to recognize your browser and to provide convenience and other features to you. We use cookies to save you time while using the Website, remind us who you are, and track and target user interests in order to provide a customized experience. Cookies also allow us to collect Non-Personal Information from you, like which pages and applications you visited and what links you clicked on.
• “Pixel tags” allow us to measure and improve our understanding of visitor traffic and behaviour on our Website, as well as give us a way to measure our promotions and performance.

If you are concerned about the storage and use of cookies, you may be able to direct your internet browser to notify you and seek approval whenever a cookie is being sent to your web browser or hard drive. You may also delete a cookie manually from your hard drive through your internet browser or other programs. Please note, however, that some parts of our Website will not function properly or be available to you if you refuse to accept a cookie or choose to disable the acceptance of cookies.

You can also choose not to provide us with certain information, but then you may not be able to participate in or utilize certain activities, such as receiving email alerts, post comments to our websites, creating a user profile, performing searches or queries, sending messages, or communicate with us.

Keeping your information secure

To demonstrate our commitment to ensuring that your Personal Data is secured, we have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse, and alteration of the information under our control.

In the unfortunate event that your “personally identifiable information” (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by e-mail (at our sole and absolute discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.

Links to other websites

Our Website may link to or contain links to other third-party websites. However, you should note that we do not have any control over such websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this Privacy Policy. You should exercise caution and review the privacy statement(s) applicable to the websites before providing your Personal Data.

Keeping Your Personal Data Updated

Whenever you use our website and other platforms, we aim to provide you with access to your existing data, in the case where such Data already exists. If that Personal Data is wrong, we strive to give you ways to update or delete it – unless we have to keep that Personal Data for legitimate business or legal purposes. When updating your Personal Data, we may ask you to verify your identity before we can act on your request.

We shall, at your request, confirm what Personal Data we hold about you and how such Personal Data is processed. To update your Personal Data, log in to your profile (if you have previously registered on our web services) or simply contact us using the information provided below.

Your Rights as a Data Subject

As a Data Subject, you have several rights to the following;

• Right to Know – You have the right to know what we do with your data and how your data is being used, processed, stored, etc.
• Right of Access – You have the right to request a copy of the information that we hold about you
• Right of rectification – You have a right to correct data that we hold about you that is inaccurate or incomplete
• Right to be Erased/Forgotten – In certain circumstances you can ask for the data we hold about you to be erased from our records
• Right to Restriction of Processing – Where certain conditions apply to have a right to restrict the processing
• Right of portability – You have the right to have the data we hold about you transferred to another organisation (to be reused for your purposes)
• Right to Object – You have the right to object to certain types of processing such as direct marketing/promotion
• Right to Withdraw – You have the right to withdraw your consent at any time

Dispute Resolution or Filing a Complaint

If you have any complaints regarding our compliance with this Privacy Policy, please contact our Data Protection Officer using the information in the “Contact Us” section below or send an email to privacy@hsdf.org.ng. We will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of personal information within thirty (30) days in accordance with this Privacy Policy and the applicable law and regulation.

Policy Changes and Amendments

We may, at our sole discretion, amend this Privacy Policy at any time. You should check these Policy Conditions periodically for modifications. If you access our Website after we post modifications to the Policy, then you will be bound by such modifications. Where you do not agree to any modification to the Policy, please do not continue to access our Website. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. We pledge to adopt measures that conform to best practices and standards in handling your Personal Information and not to materially change our policies and practices to make them less protective of the information collected in the past without the consent of affected persons.

Governing Laws

We are aligned with the provisions of the Nigeria Data Protection Regulation, 2019 (Regulation), which governs the use and protection of Personal Data in Nigeria. According to the Regulation, HSDF shall notify NITDA within 72 hours of knowledge of a breach of security leading to accidental or unlawful destruction, loss, alteration unauthorized disclosure of, or access to your Personal Data.

If you feel that your Personal Data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your Personal Data, you have a right to lodge a complaint with the NITDA using the contact details below.

National Information Technology Development Agency

Tel: +234929220263, +2348168401851, +2347052420189

Email: info@nitda.gov.ng

Website: www.nitda.gov.ng

Contact & Opt-Out Information

You may contact us as provided below if:

• you have questions or comments about our Privacy Policy.
• wish to make corrections to any personally identifiable information you have provided.
• want to opt out from receiving future correspondence, including emails, from us or our affiliated entities; or
• wish to withdraw your consent to share your personally identifiable information with others.

All questions, comments and requests regarding privacy policy should be directed to the HSDF DPO by sending an email to privacy@hsdf.org.ng