PRIVACY POLICY

1. INTRODUCTION

Welcome to Lendivel ("we," "us," "our," or "Company"). We are reimagining healthcare through a retainer-based, continuous care model that prioritizes prevention, early detection, and long-term health outcomes rather than episodic treatment.

Unlike traditional healthcare where you pay per visit and see different providers each time, Lendivel connects you with a dedicated, multidisciplinary Care Team (doctors, nutritionists, physiotherapists, psychologists, and specialists) who work together continuously to understand your health, track meaningful changes in your condition and lifestyle, and intervene proactively before problems escalate.

Our commitment to you:

• Comprehensive health management through coordinated teamwork
• Prevention-focused care with active intervention when needed
• Continuous monitoring that connects daily habits, lifestyle factors, and health outcomes
• Rapid response to health concerns and changes
• Absolute protection of your health information and privacy

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal and health information. Your trust is fundamental to our model, and we protect it with the highest standards.

Please read this carefully. By using Lendivel, you are entrusting us with sensitive health information. We take that responsibility with utmost seriousness.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Contact Information:

• Name, email address, phone number, WhatsApp number
• Physical address and location data
• Any other information you voluntarily provide when contacting us

Health Information:

• Complete medical history and current health concerns
• Symptoms, diagnoses, medical conditions, and health trends
• Treatment preferences and comprehensive lifestyle factors (diet quality and patterns, exercise type and frequency, sleep duration and quality, stress levels, activity levels, daily routines)
• Current and past medications with dosages, frequency, and adherence patterns
• Medication allergies and adverse reactions with severity details
• All past surgeries, hospitalizations, and medical procedures with outcomes
• Health assessment results, diagnostic findings, and test results
• Detailed information shared during consultations with your Care Team (doctors, nutritionists, physiotherapists, psychologists, specialists)
• Daily health tracking data (vital signs, symptom patterns, wellness metrics)
• Your health and prevention goals
• Behavioral and lifestyle patterns that impact your health and wellbeing

Mental Health Information (critical for comprehensive care):

• History of depression, anxiety, or other mental health conditions
• Any suicidal thoughts, self-harm behavior, or psychiatric hospitalization
• Current mental health treatment or therapy
• Substance use patterns and triggers

Account Information:

• Login credentials (username, password)
• Profile information you create in our app or platform
• Payment information (processed securely through third-party processors)
• Communication preferences

Other Information:

• Any documents, files, or attachments you upload
• Messages and communications with our Virtual Assistants and Care Team members

2.2 Information Collected Automatically

Cookies and Tracking Technologies:

• Browser type and operating system
• Pages visited and time spent on our website
• Links clicked
• Referral source (how you found us)
• Device identifiers
• IP address and location data (approximate)

Through Third-Party Services:

• Google Analytics: We use Google Analytics to understand how visitors use our website, analyze traffic patterns, and improve user experience. Google Analytics sets cookies to track your activity.
• Tawk.to: Our live chat and customer support tool collects interaction data, conversation history, and device information to provide customer support.

Email Communications:

• When you receive emails from us, we may track whether emails are opened and which links are clicked

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

3.1 Providing Services

• Delivering healthcare consultations and retainer-based care
• Assigning appropriate Care Team members
• Tracking health progress and treatment outcomes
• Sending appointment reminders and follow-up communications
• Processing payments and managing billing

3.2 Improving Our Services

• Analyzing website traffic and user behavior
• Identifying technical issues and improving website performance
• Personalizing your experience and content recommendations
• Developing new features and services

3.3 Communication

• Responding to your inquiries and support requests
• Sending promotional materials, newsletters, and updates (with your consent)
• Notifying you of changes to our policies or services

3.4 Legal Compliance

• Complying with applicable laws and regulations
• Protecting against fraud, abuse, and security threats
• Enforcing our Terms and Conditions
• Responding to legal requests from authorities

3.5 Healthcare Purposes

• Maintaining medical records and continuity of care
• Consulting with specialists or other healthcare providers (with your consent)
• Quality assurance and clinical research (anonymized data only)
• Preventing duplicate treatments and ensuring patient safety

4. COOKIES AND TRACKING

4.1 What Are Cookies?

Cookies are small files stored on your device that help websites recognize you and remember your preferences. They allow us to provide a better experience and understand how you use our site.

4.2 Types of Cookies We Use

Essential Cookies (No Consent Required - Necessary for Service):

• Session cookies that keep you logged into your account securely
• Security cookies that protect against unauthorized access and fraud
• Cookies required for basic website and app functionality
• These cookies are strictly necessary; disabling them may prevent service access

Analytics Cookies (Consent Required - Helps Us Improve):

• Google Analytics cookies that track how you use our website and app
• Information collected: pages visited, time spent, features used, user journey
• Purpose: understand user behavior, identify technical issues, improve service quality
• Data is anonymized and does not identify you personally
• You can opt-out without losing core service access

Functional Cookies (Consent Required - Enhanced Experience):

• Tawk.to cookies for live chat and customer support functionality
• Cookies that remember your preferences (language, theme, accessibility settings)
• Purpose: provide personalized, convenient experience
• These enhance service but are not strictly essential

Marketing Cookies (Consent Required - Only if You Consent):

• Cookies used to track your interests and deliver targeted content
• Cookies from third-party platforms if you share content on social media
• Purpose: show you relevant information about Lendivel services
• These are completely optional and don't affect your core care

4.3 Your Control Over Cookies

When you first visit Lendivel, you will see a cookie consent banner. You can:

• Click "Yes" - Accept all cookies including analytics and tracking
• Accept essential only - Use core service with only essential cookies
• Manage preferences - Choose which specific types of cookies you accept
• Change anytime - Adjust your cookie preferences in account settings or browser

What "Yes" means:

• You consent to all cookie types (essential, analytics, functional, marketing)
• Tracking and analytics are enabled to improve Lendivel
• Your choice is saved and you won't see the banner again

How to manage cookies in your browser:

• Visit your browser settings (Chrome, Safari, Firefox, Edge all have cookie controls)
• Search for "Cookies" or "Site data" in settings
• You can block, delete, or allow cookies by website
• Note: Blocking essential cookies may affect Lendivel's functionality

For enhanced privacy:

• Use browser "Do Not Track" feature if available
• Consider privacy-focused browsers or extensions
• Review your cookie preferences periodically as websites update practices

6A. DATA STORAGE AND ARCHITECTURE

6A.1 Where Your Data Is Stored

Your health information and account data is securely stored in:

• Primary storage: Lendivel's secure cloud infrastructure with encryption
• Backup systems: Redundant backup infrastructure for disaster recovery and business continuity
• Communication systems: WhatsApp messages (end-to-end encrypted by WhatsApp), email servers (standard encryption)
• Chat support: Tawk.to servers for customer support interactions
• Analytics: Google Analytics servers (anonymized, non-identifiable data only)

All storage locations maintain enterprise-grade security, encryption, and access controls.

6A.2 Data Flow Through Lendivel

Your information is managed as follows:

1. Entry point: Data enters via WhatsApp, app, email, phone, or website
2. Initial processing: Virtual Assistant securely logs and documents your information
3. Care Team access: Your Care Docket syncs securely to your Care Rep and authorized team members
4. Ongoing management: Data stored in your secure medical record with access tracking
5. Analytics: Anonymized usage data helps us improve our service
6. Customer support: Tawk.to interactions available for service support purposes

6A.3 Third-Party Service Providers

Lendivel partners with trusted service providers to deliver your care:

Essential Infrastructure & Services:

• Cloud infrastructure provider: Provides secure data storage and backup
• Payment processing: Securely processes your monthly retainer payments
• Email service: Delivers appointment reminders and care communications
• Communication platforms: WhatsApp (for your convenience), supporting your care updates

Analytics & Support Tools:

• Google Analytics: Tracks website usage to improve our service (anonymized data only)
• Tawk.to: Live chat support for answering your questions

All third parties:

• Have signed data protection agreements with Lendivel
• Are prohibited from using your data for any purpose other than service delivery
• Maintain their own security standards and privacy policies
• Have limited access to only the data necessary for their function

6A.4 Data Sharing Restrictions

Your health data is NEVER shared with:

• Marketers, advertisers, or commercial companies
• Insurance companies (unless you explicitly authorize)
• Your employer or HR departments
• Family members (unless you authorize)
• Government agencies (except if legally required, with notice where possible)
• Anyone outside your authorized Care Team

Your data is shared only with:

• Your assigned Care Rep (primary healthcare provider)
• Authorized specialists and Care Team members (only with your knowledge)
• External providers you're referred to (with advance notification to you)
• Legal authorities (only if legally required by law)

6. DATA SECURITY

6.1 Security Architecture and Protections

Lendivel implements comprehensive security measures to protect your health information:

Data Protection:

• End-to-end encryption for all data in transit (HTTPS/TLS protocols)
• Encryption at rest for all stored health data
• Secure database architecture with role-based access controls
• Regular security audits and vulnerability assessments
• Intrusion detection and prevention systems
• Professional liability and cyber insurance coverage

Access Control:

• Role-based access controls—staff only access data necessary for your care
• Multi-factor authentication for all staff accounts
• Comprehensive audit logs tracking all data access
• Automatic session timeouts for security
• Strong password requirements and regular security updates

System Protections:

• Enterprise firewalls and network segmentation
• Automated security patches and system updates
• Secure backup procedures with redundancy
• Disaster recovery systems to prevent data loss
• Regular penetration testing and security assessments

Staff Accountability:

• All staff complete healthcare data security training annually
• Binding confidentiality and data protection agreements
• Clear protocols for data handling and security
• Mandatory incident reporting for any security concerns
• Regular security awareness and compliance training

6.2 Important Security Limitations

What we cannot guarantee:

• No security system is absolutely immune to sophisticated attacks
• Determined adversaries may overcome even strong protections
• Human error or internal threats, while prevented through rigorous procedures, cannot be completely eliminated
• Unauthorized access is extremely unlikely but theoretically possible

Your responsibility:

• Keep your login password confidential and strong
• Never share your account credentials with anyone
• Log out after using shared or public devices
• Report suspicious account activity immediately
• Use secure internet connections (avoid public WiFi for sensitive access)
• Update your contact information if compromised

6.3 Data Breach Response

In the event of a data breach, Lendivel will:

• Immediately investigate and contain the breach
• Determine scope and types of data affected
• Notify affected individuals within 30 days of discovery
• Provide clear information about the breach and protective steps
• Notify relevant regulatory authorities as required by law
• Implement corrective measures to prevent recurrence
• Maintain detailed incident documentation

You will receive notification including:

• What data was compromised
• When the breach occurred
• What steps Lendivel took in response
• What steps you should take to protect yourself
• Contact information for questions or concerns

7. DATA RETENTION AND YOUR RIGHTS

7.1 How Long We Keep Your Information

Health Records and Medical Data:

• Retained for the duration of your care relationship plus minimum 7 years
• Aligns with Nigerian healthcare standards and regulatory requirements
• Extended retention supports continuity of care and legal protection
• If you return to Lendivel, your complete health history is available

Account and Profile Information:

• Retained while your account is active
• Deleted within 90 days of account closure (unless legally required)
• May be retained longer if needed for billing disputes or legal matters

Communication Records:

• WhatsApp messages: Governed by WhatsApp's retention policies (encrypted, limited staff access)
• Email: Standard email retention policies; you may request deletion
• Chat support: Retained for 2 years, then securely deleted
• Appointment notes and call records: Retained with your medical record (7 years minimum)

Payment and Billing Records:

• Invoices and receipts: 7 years (Nigerian tax and legal requirements)
• Payment information: Not stored long-term; deleted per payment processor standards

Analytics and Usage Data:

• Google Analytics: 26 months (automatic deletion after)
• Website usage: Anonymized for service improvement only

7.2 Your Right to Request Deletion

You may request deletion of your data by:

• Emailing support@lendivel.com with "Data Deletion Request" in the subject
• Providing your name, email, and account information
• Lendivel will respond within 30 days

Important limitations:

• Medical records must be retained 7 years for care continuity and legal protection
• Billing records retained 7 years per Nigerian regulations
• Anonymized or aggregated data cannot be individually deleted
• Data under legal hold or litigation cannot be deleted until released

7.3 Data Anonymization and Secondary Use

After retention periods or upon request, Lendivel may anonymize your data for:

• Service improvement and quality assurance
• Identifying health trends and patterns
• Care Team training and clinical protocol development
• Improving Lendivel's healthcare delivery

Anonymized data cannot identify you individually and is treated under different privacy protections.

8. YOUR RIGHTS AND CHOICES

8.1 Your Data Rights

Depending on your location, you may have the following rights:

Right to Access:

• You can request a copy of the personal information we hold about you

Right to Correction:

• You can request that we correct inaccurate or incomplete information

Right to Deletion:

• You can request deletion of your personal information (subject to legal and healthcare record-keeping requirements)

Right to Data Portability:

• You can request your data in a portable format to transfer to another service

Right to Withdraw Consent:

• You can withdraw consent for marketing communications and non-essential data processing at any time

Right to Object:

• You can object to certain types of data processing

8.2 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

• Email: support@lendivel.com
• WhatsApp: 098-765-4321
• Website: https://www.lendivel.com

We will respond to your request within 30 days.

8.3 Managing Your Preferences

You can update your information and communication preferences by:

• Logging into your account and editing your profile
• Contacting our support team
• Using the unsubscribe link in our emails

9. INTERNATIONAL DATA TRANSFERS

If you are accessing our services from outside Nigeria, your information may be transferred to, stored in, and processed in Nigeria or other countries where we operate. By using our services, you consent to the transfer of your information to countries outside your country of residence, which may have different data protection rules.

10. GDPR COMPLIANCE (for EU Users)

If you are located in the European Union, you have additional rights under the General Data Protection Regulation (GDPR):

• Legal Basis for Processing: We process your health information based on your consent and our legitimate interest in providing healthcare services
• Data Protection Officer: You can contact our privacy team with GDPR-related questions
• Right to Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority
• Standard Contractual Clauses: We use appropriate safeguards for international data transfers

11. NIGERIAN DATA PROTECTION

As a company operating in Nigeria, we comply with NITDA (National Information Technology Development Agency) guidelines on data protection and privacy. We are committed to:

• Protecting personal data from unauthorized processing
• Ensuring data accuracy and security
• Respecting user consent and preferences
• Responding to data protection inquiries within 30 days

12. CHILDREN'S PRIVACY

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we discover that a child has provided us with personal information, we will delete such information and terminate the child's account. If you believe we have collected information from a child, please contact us immediately.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be clearly communicated to you through:

• A prominent notice on our website
• An updated "Last Updated" date at the top of this policy
• Email notification to registered users (for significant changes)
• Your continued use of our services after changes constitutes your acceptance of the updated Privacy Policy

Current Version: 1.0 (Effective November 8, 2025)

We recommend reviewing this policy regularly to stay informed about how we protect your information.

14. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Lendivel

• Email: support@lendivel.com
• Alternative Email: info@lendivel.com
• WhatsApp: 098-765-4321
• Website: https://www.lendivel.com

Response Time: We will acknowledge your inquiry within 2-3 business days and provide a full response within 30 days.

End of Privacy Policy