Purpose of the Policy

This Privacy Policy explains how Kennedia HMO (hereafter referred to as “KHMO,” “Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects your personal data through your use of our mobile application, website, and related digital platforms (collectively, the “Service”). This includes any data you may provide when using our Service or communicating with us.

Please read this Privacy Policy carefully together with any other privacy or fair processing notice we may provide at the time of collecting or processing your data. These documents work together to help you understand how and why we use your personal data.

By using our Service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your information in accordance with it.

Kennedia HMO is responsible for your personal data and is committed to protecting your privacy and ensuring compliance with applicable data protection laws, including the Nigeria Data Protection Act (NDPA) 2023.

Types of Data Collected

1. Personal Data

While using our Service, we may collect personally identifiable information that can be used to contact or identify you (“Personal Data”). This includes, but is not limited to:

• Contact Information (e.g., name, phone number, address, and email address);
• Date of Birth, marital status, and details of your dependents;
• Dependent Information (for dependents aged 0–21 years, including those under 13 years, collected only with the consent of the parent or legal guardian);
• Financial Information (e.g., bank account details, debit/credit card numbers, balances, and payment information for healthcare services);
• Government Identification Numbers (e.g., Driver’s License, National ID, Voter’s Card);
• Benefits Coverage and Health Information (e.g., health insurance status, medical services received, claims history);
• Employment or academic details (where applicable);
• Geo-location and demographic data.

2. Usage Data

We may also collect information on how the Service is accessed and used (“Usage Data”). This may include:

• Device information, browser type, IP address, pages visited, and duration of visits;
• Cookies and similar technologies;
• Unique device identifiers and diagnostic data.

We also collect payment-related information, such as premium payments, reimbursements, and related transaction details.

Additionally, we may receive information about you and your dependents from third-party service providers, such as healthcare providers, claims administrators, and other partners involved in delivering health services.

We retain personal data only as long as is required by our business practices, legal obligations, or as necessary to fulfill the purposes described in this policy.

Use of Data

We use collected data for the following purposes:

• To provide, administer, and manage your health plan or related services;
• To verify your identity and ensure proper enrollment;
• To process payments, reimbursements, and claims;
• To provide customer support and respond to your requests;
• To notify you about updates, changes, or improvements to our Service;
• To monitor, analyze, and improve our Service performance;
• To comply with legal and regulatory obligations;
• To detect, prevent, and address fraud or technical issues.

We ensure that all personal data is accurate, updated, and not retained for longer than necessary.

You may request correction or restriction of processing of your personal data if it is inaccurate or no longer needed.

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside your state or country, where data protection laws may differ.

If you are located outside Nigeria and provide information to us, you acknowledge and consent that your data will be transferred to and processed in Nigeria.

We take appropriate safeguards to ensure your data is adequately protected during such transfers.

Disclosure of Data

We do not sell or rent your personal data.

We may share your data only with:

• Trusted third parties assisting us in providing or improving our services (e.g., healthcare providers, IT service vendors, payment processors);
• Regulatory authorities, as required by law;
• Business partners or affiliates that process data under strict confidentiality and security obligations.

All third-party service providers are required to protect your information and use it only for authorized purposes.

Legal Requirements

We may disclose your data in good faith when necessary to:

• Comply with a legal obligation or regulatory request;
• Protect and defend the rights or property of Kennedia HMO;
• Prevent or investigate possible wrongdoing or fraud;
• Protect the safety of users or the public;
• Defend against legal claims or liability.

Security of Data

We implement appropriate organizational, technical, and administrative safeguards to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

We also maintain incident response procedures and will notify you and relevant regulators of any confirmed data breach as required by law.

While we strive to use commercially reasonable measures to protect your data, no method of electronic storage or transmission is 100% secure, and we cannot guarantee absolute security.

Children’s and Dependents’ Privacy

Our Service may involve the collection of personal data for dependents and beneficiaries under your health plan, including minors.

• We collect and process information for dependents aged 0–21 years (including those under 13 years) strictly with the consent and authorization of the parent, guardian, or principal enrollee.
• We do not knowingly collect personal information directly from children under 13 years without verifiable parental consent.
• Parents or guardians who believe that we have inadvertently collected such information without consent should contact us immediately, and we will promptly delete it.

Your Rights

Depending on applicable laws, you have the right to:

• Access and obtain a copy of your personal data;
• Request correction or deletion of inaccurate or unnecessary information;
• Object to or restrict certain types of data processing;
• Withdraw consent (where consent is the basis of processing);
• Lodge a complaint with the National Information Technology Development Agency (NITDA) or another relevant authority.

To exercise any of these rights, please contact us via the details below.

Governing Laws

This Privacy Policy and any dispute arising from it are governed by the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act (NDPA) 2023 and any subsequent amendments.

Changes to This Privacy Policy

We may update this Privacy Policy periodically. Any changes will be posted on this page with an updated “Last Updated” date.

Your continued use of our Service after such updates constitutes your acknowledgment and acceptance of the revised policy.

Contact Us

If you have any questions, requests, or complaints regarding this Privacy Policy or our data protection practices, please contact us:

By Email: info@kennediahmo.com

Website: https://www.kennediahmo.com

Mailing Address: 14b Kingsley Emu Street, Off Chris Efuyemi Onanuga Street, Lekki Phase 1, Lagos State, Nigeria