We are committed to the protection of your privacy while you use our Website.
- Data processor: Data Processor is the Party responsible for the collection of information described herein. Data Processor shall be referred to either by Data Processor’s name or “Data Processor.”
- Operator: Operator is the publisher, owner, and operator of the Website and is the Party responsible for the collection of information described herein, along with Data Processor. Operator shall be referred to either by Operator’s name or “Operator”. If Operator or Operator’s property shall be referred to through first-person pronouns, it shall be through the use of the following: us, we, our, ours, etc.
- Products and Services: “Products” and/or “Services” means any offerings that we make available for purchase on or through the Website.
- Personal data: “Personal DATA” means personal data and information that we obtain from you in connection with your use of the Website that is capable of identifying you in any manner.
The Party responsible for the processing of your personal data is as follows:
The Data Processor may be contacted as follows:
3A , Olamuyiwa Street, Off Oba Babington Ashaye Cresent, Omole Phase 1, 100213, Lagos; 070022332233; firstname.lastname@example.org
The name, address, telephone number, and email address of the Operator, or the person or entity running the Platform are as follows:
Orius; Orius HQ, Abuja, F.C.T; +2349150481078; email@example.com
Please be advised the data processing activities take place in Nigeria. Data may also be transferred to (our remote staff and contractors) and companies within Nigeria or outside of Nigeria, but will only be done so in a manner that complies with Nigeria’s Data Protection Regulation or NDPR. Also, your personal information will continue to be protected by means of contracts or agreements that we have in place with these individuals or entities.
Depending on how you use the Platform, you will be subject to different types of Personal Data collected and different manners of collection:
a) Registered users: You, as a user of the Platform, may be asked to register in order to use the Platform or to purchase the Products or Services available on offer. During the process of your registration, we will collect some of the following Personal Data from you through your voluntary disclosure:
Personal Data may be asked for in relation to:
-Interaction with our representatives in any way
-Receiving notifications by text message or email about marketing
-Receiving general emails from us
-Commenting on our content or other user
-Generated content on the Platform, such as blogs, articles, photographs or videos, or participating in our forums, bulletin boards, chat rooms or other similar features
Or the following other forms of participation:
-Users can comment on articles on the Platform’s blog
-Users can also contribute, make remarks or give feedback on the Platform’s Community.
b) Unregistered users: If you are a passive user of the Platform and do not register for any purchases or other Service, you may still be subject to certain passive data collection (“Passive Data Collection”). Such Passive Data Collection may include through cookies, as described below, IP address information, location information, and certain browser data, such as history and/or session information.
c) All users: The Passive Data Collection that applies to Unregistered users shall also apply to all other users and/or visitors of the Platform.
d) Sales & billing information: In order to purchase any of the Products or Services on the Platform, you will be asked to provide certain credit information, billing address information, and possibly additional specific information so that you may be properly charged for your purchases. This payment and billing information may be stored by Orius for the following period: 30 days. If so, it will be used exclusively to assist you with making future purchases with us.
f) Email marketing: You may be asked to provide certain Personal Data, such as your name and email address, for the purpose of receiving email marketing communications. This information will only be obtained through your voluntary disclosure and you will be asked to affirmatively opt-in to email marketing communications.
g) User experience: From time to time we may request information from you to assist us in improving the Platform, and the Products and Services we offer, such as information concerning your mental state, thoughts and feelings or your particular preferences.
h) Content interaction: Our Platform may allow you to comment on the content that we provide or the content that other users provide, such as blogs, multimedia, or forum posts. If so, we may collect some Personal Data from you at that time, such as, but not limited to, username or email address.
i) Combined or aggregated information: We may combine or aggregate some of your Personal Data in order to better serve you and to better enhance and update the Platform for your and other consumers’ use. We may also share such aggregated information with others, but only if that aggregated information does not contain any Personal Data.
j) Other information: In addition to collecting the Personal Data as already described herein, we may also collect the following Personal Data:
-Mental health history and challenge(s)
-Oher information that may be deemed reasonable for the purpose of appropriately serving your mental health needs.
Cookies: We may collect information from you through automatic tracking systems (such as information about your browsing preferences) as well as through information that you volunteer to us (such as information that you provide during a registration process or at other times while using the Platform, as described above).
Technical cookies: Technical cookies, which can also sometimes be called HTML cookies, are used for navigation and to facilitate your access to and use of the Platform. They are necessary for the transmission of communications on the network or to supply services requested by you. The use of technical cookies allows the safe and efficient use of the Platform. You can manage or request the general deactivation or cancelation of cookies through your browser. If you do this though, please be advised this action might slow down or prevent access to some parts of the site.
Cookies may also be retransmitted by an analytics or statistics provider to collect aggregated information on the number of users and how they visit the Platform. These are also considered technical cookies when they operate as described.
Temporary session cookies are deleted automatically at the end of the browsing session – these are mostly used to identify you and ensure that you don’t have to log in each time – whereas permanent cookies remain active longer than just one particular session.
Support in configuring your browser: You can manage cookies through the settings of your browser on your device. However, deleting cookies from your browser may remove the preferences you have set for this Platform.
For further information and support, you can also visit the specific help page of the web browser you are using:
–Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
Log data: Like all websites and mobile applications, this Platform also makes use of log files that store automatic information collected during user visits.
The different types of log data could be as follows:
–Internet protocol (IP) address;
–Type of browser and device parameters used to connect to the Platform;
–Name of the Internet Service Provider (ISP);
–Date and time of visit;
–Web page of origin of the user (referral) and exit;
–Possibly the number of clicks.
The aforementioned information is processed in an automated form and collected in an exclusively aggregated manner in order to verify the correct functioning of the Platform, and for security reasons. This information will be processed according to the legitimate interests of the Data Controller.
For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Data such as IP address, which could be used, in accordance with applicable laws, in order to block attempts at damage to the Platform or damage to other users, or in the case of harmful activities or crime. Such data are never used for the identification or profiling of the user, but only for the protection of the Platform and our users. Such information will be treated according to the legitimate interests of the Data Controller.
We may utilize third-party service providers (“Third-Party Service Providers”), from time to time or all the time, to help us with the Platform, and to help serve you. We may use Third-Party Service Providers to assist with information storage (such as cloud storage). We may provide some of your Personal Data to Third-Party Service Providers in order to help us track usage data, such as referral websites, dates and times of page requests, etc. We use this information to understand patterns of usage of, and to improve, the Platform. We may use Third-Party Service Providers to host the Website or Apps. In this instance, the Third-Party Service Provider will have access to your Personal Data. We may use Third-Party Service Providers to fulfil orders in relation to the Platform.
Some of our Third-Party Service Providers may be located outside of Nigeria and may not be subject to Nigerian privacy laws.
The countries or regions in which our Third-Party Service Providers may be located include:
UK and Europe, United States and North America, China and Asia, Africa, South America, Australia and Oceania.
Your Personal Data will not be sold or otherwise transferred to other third parties without your approval.
In general, you may request that we do not share your Personal Data with third parties. Please contact us via email, if so. Please be advised that you may lose access to certain Services that we rely on third-party providers for.
We use secure physical and digital systems to store your Personal Data when appropriate. We ensure that your Personal Data is protected against unauthorized access, disclosure, or destruction. Please note, however, that no system involving the transmission of information via the internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Data very seriously. We take all reasonable steps to protect your Personal Data.
The systems that we use to store your information include but are not limited to:
-We ensure only administrative/operational staff and our mental health professionals have access to personal user information data, and we conduct frequent internal security audits to make sure we never have any security breaches.
-Personal Data is stored throughout your relationship with us. We delete your Personal Data upon request for cancelation of your account or other general request for the deletion of data.
-In the event of a breach of your Personal Data, you will be notified in a reasonable time frame, but in no event later than two weeks, and we will follow all applicable laws regarding such breach.
We primarily use your Personal Data to help us provide a better experience for you on the Platform and to provide you the Services and/or information you may have requested, such as use of the Platform. Information that does not identify you personally, but that may assist in providing us broad overviews of our customer base, will be used for market research or marketing efforts. Such information may include, but is not limited to, interests based on your cookies.
Personal Data that may be considered identifying may be used for the following:
-Improving your personal user experience
-Communicating with you about your user account with us
-Marketing and advertising to you, including via email
-Fulfilling your purchases
-Providing customer service to you
-Advising you about updates to the Platform or related Services.
Although our policy is to maintain the privacy of your Personal Data as described herein, we may disclose your Personal Data if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion.
Such cases may include, but are not limited to:
-To satisfy any local, state, or Federal laws or regulations
-To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies
-As may be necessary for the operation of the Platform
-To generally cooperate with any lawful investigation about our users
Minors are NOT permitted to purchase Therapy Services on the Platform by themselves, except by their parent of legal guardian. In the event of the express permission and supervision of a parent or legal guardian, we may attend to and collect information from minors (children).
The information we collect as regards minors is as follows:
-The minor’s name
-The minor’s birthdate
-The minor’s medical/mental health history and challenges
-Related information that may help the Therapist fully empathize with the minor, to enable the administration of appropriate clinical/counselling advice/guidance and treatment plans.
Information collected from minors in accordance with this clause is collected to help us enhance all user experiences and to improve the Platform.
We do not require minors to disclose any further information than is reasonably necessary to interact with the Platform and its Services. Parents or legal guardians of minors may review the Personal Data of their minor and have it deleted at their request. They may also agree to collection and use of information, without consenting to disclosure to any other party. They may also refuse to permit any further collection or use of such information by sending us an email at firstname.lastname@example.org.
From time to time, we may send you informational or marketing communications related to the Platform such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email: email@example.com. You may also click the opt-out or unsubscribe link which will be provided at the bottom of any and all such communications.
Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of the Platform or about your account with us.
By providing any Personal Data to us, or by using the Platform’s Services in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically NOT be considered SPAM, as that term is legally defined.
If you wish to modify or delete any information we may have about you, or you wish to simply access any information we have about you, you may do so by contacting us at the following email address: firstname.lastname@example.org.
You have many rights in relation to your Personal Data. Specifically, your rights are as follows:
– The right to be informed about the processing of your Personal Data
– The right to have access to your Personal Data
– The right to update and/or correct your Personal Data
– The right to portability of your Personal Data
– The right to oppose or limit the processing of your Personal Data
– The right to request that we stop processing and delete your Personal Data
– The right to block any Personal Data processing in violation of any applicable law
– The right to launch a complaint with the Nigerian Data Protection Bureau (NDPB) in Nigeria or applicable data protection authority in another jurisdiction.