1.INTRODUCTION
One Global Medical Technology Ltd and its affiliates (“Helium Health,” “We,” “Us,” or “Our”) provide a healthcare technology ecosystem comprising electronic health records (“HeliumOS”), practice tools, patient portals and telehealth (“HeliumDoc”), financing (“HeliumCredit”), AI/analytics (e.g., “HeliumCoPilot”), and related services (the “Platform”).
Helium Health exists to make healthcare more connected, reliable, and safe. The systems We provide allow healthcare professionals to record, coordinate, and improve care, while ensuring that the information entrusted to Us is managed responsibly under the strongest privacy protections.
As part of this Platform, Helium Health is the lead organisation in the FOR M(om) Program, a consortium with SOLINA and AFRIDA. The Program aims to improve maternal care quality, reduce maternal mortality, and strengthen systems for safer childbirth by providing healthcare financing and digital tools for public and private health facilities.
We process your information in accordance with applicable global data protection laws, including, amongst others, the Nigeria Data Protection Act, 2023 (“NDPA”).
2. THE DATA WE PROCESS
2.1 Personal data is any information about an individual that can be used to identify that individual directly or indirectly. While you try to request personalised medical advice or share your experience from the FOR M(om) Program, We may request personal information such as name, email, phone number, location, feedback on health care services, photographs, audio, videos, and billing information from you to carry out Our objectives, contact, or identify you. We obtain the following information from you:
- Contact information: full name, email address, phone number;
- Information about health history and related data;
- Location Information;
- Feedback on health care services, including photographs, written, audio or video feedback; and
- Billing information.
3. SENSITIVE PERSONAL DATA
We process sensitive data (e.g., health data) only with a lawful basis.
4. RELEVANT AFFILIATE PRODUCTS
Your healthcare facilities may be supported through Our HeliumOS and HeliumCredit products. Our HeliumOS product provides end-to-end digitalisation of medical records and hospital operations, allowing healthcare providers to access critical patient information quickly and easily. HeliumOS’s privacy notice can be accessed here. Additionally, HeliumCredit is a loan facility that allows healthcare facilities to access financial options that suit their needs. You can read HeliumCredit’s Privacy Notice here.
5. LAWFUL BASES FOR PROCESSING DATA
- Legitimate interest-where necessary for Our business operations, provided your rights are not overridden.
- Consent-where you have given explicit consent for a specific purpose.
- Contract-necessary to perform a contract with you or take steps at your request before entering into one.
- Public health-to support initiatives aimed at protecting and promoting public health.
- Legal obligation-where processing is required to comply with applicable law.
6. PURPOSES OF PROCESSING YOUR DATA
We process your data (including, but not limited to, your personal data, anonymized data, pseudonymised data, and any other variations or forms of your data) for any or all of the following purposes:
| Purpose of Processing | Lawful Bases |
| – To collect, store and share your experience about the FOR M(om) Program – To send marketing or promotional messages to you | Consent |
| – To analyse and improve the safety, security and functionality of the FOR M(om) Program or any of Our services – To enhance Our products or servicesTo improve the accuracy of Our records so that We can better understand your needs and preferences – To inform you whenever there are changes to Our terms of service – To take statistical data and analytics for Our internal useCollecting, analysing, sharing, and additional processing of your data for statistical purposes, market insights, and internal or external reporting – To support Our business objectives, (such as potential collaborations, partnerships, or other opportunities) including, but not limited to, collecting, analysing, sharing, and additional processing of your data for the following activities: i) sending you marketing or promotional communications about Helium Health’s products, services, and other offerings; ii) generating marketing and data-driven insights; iii) marketing enhancement of Helium Health’s products or services; iv) purposes related to Helium Health’s legitimate interests; v) statistical purposes, market research and analytics;supporting Helium Health’s business interests, legitimate interests, and other interests | Legitimate interest |
| – Collecting, analysing, sharing, and additional processing of your data for statistical purposes, market insights, and internal or external reporting – Supporting Our business objectives, (such as potential collaborations, partnerships, or other opportunities) including, but not limited to, collecting, analysing, sharing, and additional processing of your data for the following activities: i) medical research, clinical research, and other forms of research or initiatives; ii) the overall advancement of healthcare in Africa and the rest of the world; iii) clinical trials and studies aimed at improving healthcare outcomes and advancing medical knowledge, amongst other objectives | Public Health |
| – To meet valid requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms – To interact with regulatory authorities or other public authorities concerning you | Legal obligation |
These purposes represent the lawful and limited ways data may be used. Most relate to providing healthcare and maintaining system integrity.
7. HOW WE USE DE-IDENTIFIED/ANONYMIZED DATA
As an integral function of the Platform, we process Health Information to create de-identified or anonymized data in accordance with NDPA, General Data Protection Regulation (“GDPR”), and Health Insurance Portability and Accountability Act (“HIPAA”) standards, as applicable. Once properly anonymized, it is no longer considered personal data under those laws.
We and Our contractual partners may use, disclose, license, aggregate, and commercialize such de-identified or anonymized data for purposes permitted by applicable law, including but not limited to:
- Supporting medical, scientific, technological, and public health advancements that improve health outcomes and strengthen healthcare systems, including participation in clinical studies, surveys, and research initiatives.
- Advancing the safe and responsible development of artificial intelligence (including large language models), analytics, and other technologies to enhance diagnosis, treatment, and healthcare delivery.
- Creating, enhancing, and commercializing products, services, and solutions across healthcare, life sciences, and other industries, and furthering Our and Our contractual partners’ business interests, for which We may receive remuneration as permitted by applicable law.
We may use, license, or share such data with public health organizations, research institutions, life sciences organizations, technology developers, third-party for-profit commercial entities, and other partners as independent controllers for purposes permitted by applicable law (e.g., research, artificial intelligence model training, product development, analytics, and commercialization of resulting outputs).
This section makes clear that once data is anonymized, it is no longer linked to you personally and can safely be used for broader purposes such as research or improving healthcare technology. You may revoke your consent for these purposes at any time by contacting us at dpco@heliumhealth.com. However, in certain cases it may not be possible to honor this request, for example, if deletion is not technically feasible because your de-identified data can no longer be traced back to you.
8. YOUR RIGHTS AS A DATA SUBJECT
As a data subject, you may have the following rights (subject to applicable law):
- Access your personal data.
- Request correction of inaccurate or incomplete data.
- Request erasure (“right to be forgotten”).
- Restrict or object to processing, including for marketing purposes.
- Request data portability.
- Withdraw consent at any time.
- Object to automated decision-making or profiling.
- Lodge a complaint with a regulatory authority.
You may exercise your rights by contacting us at info@formomnigeria.org or publichealth@heliumhealth.com (withdrawal of consent).
9. WHO WE SHARE DATA WITH
We collaborate with select third-party service providers and affiliates to provide Our service:
| Third Parties | Purpose of Data Sharing |
| Implementing Partners – SOLINA and AFRIDA | We share data with Our implementing partners to facilitate collaboration between Us and for the execution of the FOR M(om) Program |
| Funder and partners of MSD for Mothers | We share data with the MSD for Mothers funder and partners to fulfil reporting requirements, demonstrate project outcomes, ensure transparency, and facilitate ongoing support and funding for the FOR M(om) Program |
| Collaborative Partners | We collaborate with other businesses to support Our legitimate business objectives and may share your data with these partners to achieve these objectives |
| Service providers | We share data with Our service providers to deliver certain services essential for the operation of the FOR M(om) Program. These services include billing, collation, and analysis of impact stories |
| Legal and Regulatory Authorities | We disclose your personal information if We believe it is reasonably necessary to comply with a law, regulation, order, subpoena, audit, or to protect any person’s safety or to address fraud, security, or technical issues |
10. RETENTION OF YOUR DATA
We retain personal data for as long as necessary for the purposes outlined in this Privacy Notice, in line with legal requirements. Data may be retained longer where legally required, even if you request deletion. Marketing data will be deleted once you unsubscribe. We retain personal data only as long as necessary for the purposes collected, to provide services, and to satisfy legal/clinical retention obligations. De-identified/anonymized data may be retained indefinitely.
Data is held only as long as necessary to meet care, legal, or regulatory requirements. Once anonymized, information can be retained without personal risk.
11. SECURITY OF YOUR DATA
We implement technical and organisational safeguards to protect your data against loss, misuse, or unauthorised access. While no system is entirely secure, We will promptly notify you and relevant authorities in the event of a significant breach.
12. INTERNATIONAL DATA TRANSFERS
Where data is transferred outside your country of residence, We ensure appropriate safeguards are in place, such as adequacy decisions, standard contractual clauses, or regulator approval. Safeguards such as Standard Contractual Clauses and adequacy decisions are applied so that data receives the same level of protection internationally as it does locally.
13.COOKIES AND TRACKING TECHNOLOGIES
We use cookies/SDKs for session management, analytics, security, and experience. Where required, We seek consent and honor regional choices. You can manage non-essential cookies via Our banner and your browser/app settings.
14. MARKETING AND COMMUNICATIONS
We will only send marketing communications with your consent. You may opt out at any time via the unsubscribe link.
15. COMPLAINTS
If you have any inquiries or complaints, please contact Our Data Protection Officer (“DPO”) at dpco@heliumhealth.com.We will investigate and respond promptly.
16. CHANGES TO THIS NOTICE
We may update this Privacy Notice periodically. Please check the “last updated” date when reviewing.
17. CONTACT US
If you have any questions about this Privacy Notice or your rights, contact Our DPO via email at dpco@heliumhealth.com.
18. GOVERNANCE
We operate a privacy program aligned to principles of the applicable data protection laws, with records of processing, DPIAs where required, vendor due diligence, training, and audits.
Last Updated December 2025