Privacy Policy

PRIVACY POLICY

1. Introduction and Legal Status of the Platform

This Privacy Policy ("Policy") explains how SwiiftCare (the "Platform"), operated by Cnergi Software Technology Limited ("SwiiftCare"), collects, uses, stores, shares, and protects personal data.

SwiiftCare is a technology platform that facilitates access to independent healthcare professionals and manages data solely as a platform intermediary. SwiiftCare is not a healthcare provider and does not provide medical services.

In this Policy:

• "you" or "your" refers to any user of the Platform, whether a patient or healthcare practitioner;

• "personal data" means any information relating to an identified or identifiable individual;

• "health data" means personal data relating to physical or mental health and healthcare services.

This Policy is governed by the Nigeria Data Protection Act 2023 (NDPA), the National Health Act 2014, and applicable international best-practice standards (including GDPR principles).

This Policy must be read together with the Terms of Service, which contain additional provisions on platform use, provider obligations, indemnities, and limitations of liability.

2. Our Role in Healthcare and Data Processing

SwiiftCare:

• Facilitates communication between patients and independent healthcare practitioners;

• Stores, transmits, and manages data generated through use of the Platform;

• Does not provide medical advice, diagnosis, treatment, or prescriptions.

Healthcare practitioners on the Platform:

• Are independent professionals;

• Are solely responsible for clinical decisions, medical accuracy, record integrity, prescriptions, and patient outcomes.

SwiiftCare:

• Does not validate medical correctness;

• Does not supervise, direct, or control treatment;

• Is not responsible for clinical outcomes or medical judgments.

3. Data We Collect

3.1 Patients

We may collect:

• Identification and contact data: name, date of birth, gender, address, phone number, email;

• Health and medical data: symptoms, medical history, diagnoses, prescriptions, referrals, consultation notes;

• Consultation and usage data: appointment records, chat messages, audio/video session metadata, digital forms;

• Payment and transaction data: transaction references and payment status (card details are processed by third-party payment processors);

• Device and technical data: IP address, device type, operating system, browser, session duration, approximate location.

3.2 Healthcare Practitioners

We may collect:

• Professional data: name, licence number, qualifications, speciality, regulatory body;

• Verification documents: licences and credentials submitted by the practitioner;

• Financial data: bank details for payment purposes;

• Platform usage data: login records, consultation activity, communications.

4. Practitioner Verification and Credential Disclaimer

Practitioner credentials are self-submitted. SwiiftCare performs reasonable, document-based checks to support platform integrity.

SwiiftCare does not guarantee the authenticity, accuracy, completeness, or ongoing validity of practitioner credentials.

Patients acknowledge and accept this limitation when using the Platform.

Practitioners remain fully responsible for the truthfulness of submitted information and for compliance with professional and regulatory requirements.

5. Legal Basis and Explicit Consent for Health Data

Health data is classified as sensitive/special category data under applicable law.

SwiiftCare processes health data only with your explicit consent, which is obtained during account creation and before use of telemedicine features.

You may withdraw consent at any time. Withdrawal of consent may restrict or terminate access to certain Platform features, including teleconsultations.

6. How We Use Your Data

Patients

We use data to:

• Create and manage your account;

• Facilitate teleconsultations and communications with practitioners;

• Store consultation records on behalf of users;

• Process payments and transactions;

• Provide support, notifications, and service updates;

• Comply with legal and regulatory obligations.

Practitioners

We use data to:

• Enable participation on the Platform;

• Display professional profiles;

• Process payments;

• Support compliance and platform administration.

General Uses

• Fraud prevention and platform security;

• Dispute handling and legal defence;

• Anonymised or aggregated analytics for service improvement;

• Marketing communications only where you have opted in.

Health data is never sold and is never used for targeted advertising.

7. Telehealth and Technology Risk Disclosure

Telemedicine sessions may involve third-party audio/video infrastructure.

Metadata may be collected, including:

• IP address;

• Device information;

• Session duration and timestamps.

SwiiftCare cannot control:

• User device security;

• Whether users record sessions without consent;

• Internet quality or third-party network failures.

You acknowledge and accept these risks when using the Platform.

8. Third-Party Services and Data Sharing

We may share data with third parties such as:

• Payment processors;

• Audio/video communication providers;

• Cloud hosting and database providers;

• Email and SMS service providers;

• Analytics and monitoring services.

These third parties operate under their own privacy policies. SwiiftCare requires reasonable contractual and technical safeguards.

SwiiftCare is not responsible for misuse or breaches beyond its reasonable control.

9. Children and Minors

The Platform is intended for users 18 years and above.

Minors may only use the Platform with verified parental or legal guardian consent. The consenting adult controls the minor's data.

We take additional safeguards where minors' data is involved.

10. Data Retention and Deletion

Data is retained based on legal obligations and operational necessity.

Data may be retained longer for:

• Dispute resolution;

• Regulatory investigations;

• Legal compliance.

Users may request deletion where legally permissible. Deleted data may be retained in anonymised or archived form where required by law.

11. Data Security Disclaimer

We implement industry standard technical and organisational safeguards.

No system is completely secure. Users acknowledge residual risks inherent in digital systems.

Liability for breaches beyond reasonable control is limited as provided in the Terms of Service.

12. Cross-Border Data Transfers

Data may be stored or processed outside Nigeria.

Appropriate safeguards are applied.

By using the Platform, you consent to international data transfers, including to jurisdictions where third-party service providers operate.

13. Your Rights

You have the right to:

• Access your data;

• Correct inaccuracies;

• Request deletion (subject to legal limits);

• Withdraw consent;

• Object to certain processing;

• Lodge complaints with the Nigeria Data Protection Commission.

Requests may be submitted via our customer support or Data Protection Officer.

14. Updates to This Policy

We may update this Policy periodically.

Continued use of the Platform constitutes acceptance of the revised Policy.

15. Contact Information

For privacy questions, data requests, or complaints, contact: admin@swiiftcare.com