Privacy Policy

What is this Privacy Notice for?

Total health Trust Limited hereinafter referred to as (“THT” or “We”) values your Personal Data and we are committed to protecting your privacy whenever you interact with us. Please read this Privacy Notice (Notice) to understand our policies, processes, and procedures regarding the processing of your personal data. By this Notice, we explain to you how your Personal Data is collected, used, managed and transferred by THT and also explain how you can update your Personal Data with us and exercise your rights in respect of the Personal Data provided to us.

The Personal Data that we collect

We collect Personal Data that you give to us, for example, where you create an account with us, request for further information about our product, fill a form, apply for a job through our website or you subscribe to newsletters on our website. We may also automatically collect some technical information when you visit our websites such as your IP address, and information about your visit, such as the pages that you viewed. This information helps us understand customer interests and helps us improve our website. When you visit our site, the pages that you look at, and a short text file called a cookie, are downloaded to your computer. By visiting and using our websites, you agree to our use of cookies in line with THT’s policies. For more details about Cookies, please read our Cookies Policy available through this link.

How do we use your Personal Data?

We may process your Personal Data to communicate with you (including sending marketing or promotional materials to you), provide you with further information about our products and how we can serve you better, respond to your purchase orders or requests; process your application for employment with THT or to fulfil our contractual obligations to you. We may also process your Personal Data to comply with provisions of applicable laws.

Legal Basis for Processing Personal Data

The personal data we collect from our customers and how we collect it depends on the services that our customers subscribe to, how they use our services and how they interact or interface with us. This also applies to persons who are not customers of THT but have interacted with THT. We may also obtain your personal data from a third party with permission to share it with us. The processing of personal data shall be lawful if at least one of the following applies:

• Where you give us consent to the processing of your Personal Data for one or more specific purposes. You are at liberty to withdraw the consent and THT will cease to process your Personal Data where there is no other basis to do so.
• Where the processing is necessary for the performance of a contract to which the Data Subject is party to or in order to take steps at the request of the Data Subject prior to entering into a contract;
• Where processing is necessary for compliance with a legal obligation to which THT is subject;
• Where processing is necessary in order to protect the vital interests of a Data Subject or of another natural person; and
• Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in THT.

Please note that THT can rely on Legitimate Business Interest where it processes personal data of Non-Nigerians, UK nationals, residents in the European region and other countries where Legitimate Business Interest is a recognised legal basis for processing personal data.

What Constitutes your Consent?

Where processing of Personal Data is based on consent, We shall obtain the requisite consent at the time of collection of the Personal Data. You can control your data protection rights, by contacting THT. In certain instances, your ability to control your personal data will be limited, as required or permitted by applicable law. Access or control of your personal data will be dependent on the services or products you use. For example, you can choose if you wish to receive our promotional emails, newsletters, SMS messages, etc.

Who do we share your Personal Data with?

We respect your privacy, and we limit disclosure of your Personal Data to third parties. We do not sell, give or trade any Personal Data that We obtain from you to any third party for data mining or marketing purposes. However, We may share your Personal Data with companies within THT, and certain service providers engaged by us to provide services to THT subject to appropriate data security and protection. In addition, We may transfer your Personal Data to countries outside Nigeria, the EEA or the UK. In such cases, we will take reasonable steps to ensure that your personal information is treated securely, and the means of transfer shall provide adequate safeguards, for example using Standard Contractual Clauses as approved by the NDPR, the UK GDPR and/or the EU GDPR. We may also share your information where there is a regulatory or statutory obligation to disclose such Personal Data in accordance with provisions of applicable laws. Security of your Personal Data. We take security of your Personal Data seriously and we make every effort to keep your Personal Data secure. We have put in place technological and organisational procedures, including requiring our staff and any third parties who carry out any work on our behalf to comply with appropriate security standards in order to protect your Personal Data.

Retention of your Personal Data

We take appropriate measures to ensure that your Personal Data is only processed for the minimum period necessary in line with the purposes set out in this Notice or as required by applicable laws, until a time it is no longer required or has no use. Once your Personal Data is no longer required, We destroy it in a safe and secure manner.

Your Rights

THT collects Personal Data only for the purposes identified in this Policy and such information cannot be reused for any other purpose that is incompatible with the original purpose. You can exercise the following rights with respect to your Personal Data with THT:

• Request for and access your Personal Data collected and stored by THT;
• Withdraw consent at any time. For example, you can withdraw your consent to receipt of our marketing or promotional materials or unsubscribe to our newsletters;
• Object to automated decision making;
• Request rectification and modification of Personal Data kept by THT;
• Request for deletion of your Personal Data;
• Be informed of, and entitled to, provide consent prior to the processing of Personal Data for purposes other than that for which the Personal Data were collected;
• Request that THT restrict processing of your Personal Data; and
• Request for information regarding any specific processing of your Personal Data.

If you wish to exercise any of these rights, you may contact our Data Protection Officer (DPO) using the contact details provided below. You also have the right to complain to the Information Commissioner's Office (ICO) and the National Information Technology Development Agency (NITDA) if you believe that we have violated your privacy rights.

Changes to our Privacy Notice

Due to constant changes in technology and regulatory requirements, we may need to change our privacy policies or update this Notice from time to time. You will always be able to find the most recent version of our updated privacy policy on this app.

Contact & Communication

If you would like further information on this Notice, you may contact us at, contactcentre@tangerine.africa