MHF Privacy Notice

1. INTRODUCTION

One Global Medical Technology Ltd (“HeliumCredit” “We“, “Us“, or “Our“) provide a healthcare technology ecosystem: electronic health records (HeliumOS), practice tools, patient portals and telehealth (HeliumDoc), financing (HeliumCredit), AI/analytics (e.g., HeliumCoPilot), and related services (the “Platform”).

The Maternal Health Fund Program (“MHF” or the “Program”) is a Helium Health initiative implemented in partnership with the Solina Centre for International Development and Research (“SCIDaR”). The Program is designed to support healthcare facilities with financing and capacity building to improve maternal healthcare outcomes in Lagos State.

This Privacy Notice (“Notice”) guides your participation in the Program. We provide this Notice because you have a right to know what information We collect, why We collect it, how it is protected and used, and the circumstances under which it may be disclosed.

2. TERMS OF USE

You are required to comply with the provisions of the Program’s Terms of Use in relation to the information provided.

3. THE DATA WE PROCESS

Personal data means any information about an individual from which that person can be directly or indirectly identified. We do not consider personal data to include information that has been anonymised such that it does not identify a specific user.

In connection with Our services, We collect personal and financial information from you, while you participate. We ask you to provide Us with certain personal data to contact or identify you, and some automatically for Our website to function effectively.

Additionally, We also collect personal data when you provide feedback and/or report a problem.

We obtain the following information from you or through third parties:

Service UsersAll Visitors
Full name Data of birth Email address Business name Phone number   Residential address   Amount of loan needed and purpose   Loan historyThe domain name of the Internet service provider (ISP)   Date and time of your visits   Web pages visited, duration and frequency of visit   The IP address used to connect your device to the internet for identification purposes
Financial information (including, but not limited to, ATM card details, Bank Verification Number (“BVN”), etc.)   Transactional data (information relating to payment)   

4. COOKIES AND TRACKING TECHNOLOGIES

Our Program website may use cookies and other tracking technologies. Information about their usage will be specified in Our Cookie and Tracking Technologies Notice.

5. LAWFUL BASES FOR PROCESSING DATA

We are required to process your data on at least one of these lawful bases:

  • Legitimate interest: Processing your data is necessary for our legitimate interests or the legitimate interests of a third-party, provided the legitimate interest does not outweigh the data subject’s rights.
  • Consent: You have given explicit consent for Us to process your data for a specific purpose.
  • Contract: If your data processing is necessary for a contract you have with Us or because We have asked you to take specific steps before entering into that contract.
  • Legal obligation: If the processing of your data is necessary, where there is a statutory obligation on Us.
  • Public Health: We may process your data to support initiatives aimed at preventing disease, protecting health and promoting well-being of the general public.

6. PURPOSE OF PROCESSING YOUR DATA AND THE LAWFUL BASIS

We process your data (including, but not limited to, your personal data, anonymised 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 administer and manage your participation in the Program, including loan applications, disbursements, and repaymentsTo enforce Our terms of service and any terms and conditions of any other agreements for Our servicesTo run a credit check on youTo send you service-related messagesTo manage your accountTo provide credit-related services to youTo communicate with you and for customer supportTo track your repayment schedule Contract  
To help Us develop, improve, customise or restructure Our servicesTo take statistical data and analytics for Our internal useTo analyse site usage and provide, maintain, and improve the content and functionality of the siteCollecting, analysing and sharing data for statistical purposes, market insights, and internal or external reporting.Enhancing Our products or services.Collecting, using, analysing, sharing, and additionally 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 any additional processing of your data for the following activities:generating marketing and data-driven  insights;purposes related to Helium Health’s and HeliumCredit’s  legitimate interests;statistical purposes, market research and analytics;supporting Helium Health’s and HeliumCredit’s business interests, legitimate interests, and other  interests.   Legitimate interest
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:medical research, clinical research, and other forms of research  or initiatives;the overall advancement of healthcare in Africa and the rest of the world;clinical trials and studies aimed at improving healthcare outcomes and advancing medical knowledge, amongst other objectives.Public Interest
To install non-strictly necessary cookies on your deviceTo send you reminders on your repaymentTo send marketing or promotional communications about Helium Health’s and Helium Credit’s products, services, and other offeringsmarketing enhancement of Helium Health’s and HeliumCredit’s products or services Consent
 To secure your data and prevent fraud Legitimate interest, legal obligation.
To fulfil Our Know Your Customer (“KYC”) obligationTo fulfil legal requirements where neededProviding your credit information to the Credit Bureau Legal obligation

7. How We Use De-Identified/Anonymized Data

We process information to create de-identified or anonymized data in accordance with the Nigeria Data Protection Act of 2023, 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

8.1 You are vested with certain rights as a data subject. They include the right to:

  • access personal data We hold about you by requesting a copy of the personal data We hold about you;
  • rectify such information where you believe it to be inaccurate;
  • restrict the processing of your data in certain circumstances;
  • object to the processing of your data where We intend to process such data for marketing purposes;
  • where feasible, receive all personal data you have provided to Us in a structured, commonly used, and machine-readable format and transmit the information to another data controller;
  • request the erasure of your data (also known as the right to be forgotten);
  • withdraw your consent to the processing of your data;
  • not be subjected to a decision based solely on automated processing or profiling; and
  • lodge a complaint with the regulatory authority where you have reason to believe that We have violated this Privacy Notice’s term(s). (You may complain or seek redress from Us within thirty (30) days from when you first detected the alleged violation.)

8.2 You may seek to exercise any of the above rights at any time by sending Us an email at dpco@heliumhealth.com

9. WHO DO WE DISCLOSE YOUR DATA TO?

We may share your data with the following third parties:

Third Parties  Purpose of Data Sharing
CookieYesWe use CookieYes to customise our cookie banner, record user consent and manage all our Cookie compliance needs. You can read their privacy notice here.
Financial Institution(s)We collaborate with various financial institutions to develop and market Our product, and We may only use this information to market-related products unless the customer has given consent for other uses.
Legal and Regulatory AuthorityWe may 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.
Service ProvidersWe will share your personal data with service providers for them to provide services to Us, such as payment processing service providers, to conduct data processing on Our behalf, or for data verification, centralisation, or logistics purposes.
Collaborative PartnersWe collaborate with other businesses to support Our legitimate business objectives and may share your data with these partners to achieve these objectives.

10. RETENTION OF YOUR DATA

The personal data We process will be stored for as long as necessary to fulfil the purposes described in this Notice. However, We will also retain data, subject to relevant provisions of applicable laws, resolve disputes, prevent fraud and abuse, and enforce Our legal agreements and policies. In addition, We delete your data for targeted marketing purposes once you unsubscribe from Our marketing communications.

Please note that your data may be retained for a longer period, notwithstanding your request to remove it, where there is a legal requirement to do so.

11. SECURITY OF DATA

We prioritise your privacy and use advanced measures to protect your data. While no online platform is entirely foolproof, We are dedicated to safeguarding your information against loss, misuse, and unauthorised access. If a significant breach occurs, We will promptly inform you and act swiftly to address it.

12. INTERNATIONAL TRANSFER OF DATA

We may transfer personal data outside Our countries of operation. We ensure any cross-border data transfers adhere to all necessary data protection regulations. This means that before transferring personal data, We either confirm that the recipient country has robust data protection laws or, if not, employ specific contractual terms and other appropriate safeguards to protect the data. In cases where the destination country might not meet stringent data protection standards, We will leverage the relevant data transfer mechanism, seek authorisation from the regulator, or obtain your consent before proceeding and inform you of any risks.

Should you wish to learn more about how We ensure data protection during these transfers, details will be provided upon request.

13. MARKETING AND COMMUNICATIONS

We only send marketing communications to you with your consent. You can opt-out of Our marketing or object to further processing by clicking on the ‘unsubscribe’ button at the bottom of the page.

14. COMPLAINTS

If you have any inquiries or complaints, please contact Our Data Protection Officer (“DPO”) at dpco@heliumhealth.com. Our DPO will examine your concerns and update you on the resolution process.

15. CHANGES TO THIS NOTICE

We update Our privacy notice occasionally. Visitors will know this by checking the last date of the update on this page whenever they visit.

16. CONTACT US

If you have any questions relating to this Notice, your rights under this Notice, or are not satisfied with how we manage your personal data, kindly reach out to Our Data Protection Officer at dpco@heliumhealth.com .

Last updated: September 2025

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