Privacy Notice

    1.INTRODUCTION

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

    Helium Health exists to make healthcare more connected, reliable, and safe. The systems We provide allow healthcare professionals to record, coordinate, and improve care, while ensuring that the information entrusted to Us is managed responsibly under the strongest privacy protections.

    This Privacy Notice (“Notice”) applies specifically to your use of Our corporate website, www.heliumhealth.com (the “Website”). We process your information in accordance with applicable global data protection laws, including, amongst others, the Nigeria Data Protection Act, 2023 (“NDPA”).

    2.TERMS OF USE

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

    3.THE DATA WE PROCESS

    Personal data is any information about an individual that can be used to identify that individual directly or indirectly. We do not consider personal data to include information made anonymous so that it does not identify a specific individual or user.

    While using Our Website, We process personal information from you to identify you and some information may be collected automatically for Our Website to function properly. We obtain the following information from you or through third parties:

    Website Visitors
    Search queriesThe IP address used to connect your device to the internet for identification purposesName of the Internet service provider (ISP)Date and time of visitWeb pages visited, duration, and frequency of visitsBrowsing BehaviourDevice ID

    4.SENSITIVE PERSONAL DATA
     
    We do not process sensitive personal data on this Website.

    5.PRODUCTS AND SERVICES

    We offer a range of products connected to this Website, and We may also collect information from you while you use any of these products. These include:

    1. Data and Insights: This product provides access to detailed health data and insights, aiming to unify Africa’s fragmented healthcare data ecosystem through digital health tools and an expanding network of stakeholders. You can read the Data and Insights Privacy Notice here.
    2. HeliumCredit: This product is a loan facility that allows healthcare facilities access to financial options that suit their needs. You can read HeliumCredit’s Privacy Notice here.
    3. HeliumDoc: This product brings together top doctors and other healthcare professionals under one roof and provides a wide range of healthcare services, including but not limited to doctor and treatment search, in-clinic appointment booking, and telemedicine. You can read HeliumDoc’s Privacy Notice here.
    4. HeliumOS: This product provides end-to-end digitalisation of medical records and hospital operations, which allows healthcare providers to access critical patient information quickly and easily. You can read HeliumOS’s Privacy Notice here.
    5. Helium Mum: This is an Antenatal Risk Stratification (“ARS“) program, aimed at strengthening a newly developed ARS tool, that can provide differentiated care to pregnant women in Nigeria by early identification of the health risk levels for such women and determining healthcare plans for them. You can read Helium Mum’s Privacy Notice here.
    6. Helium Health-MSD For M(om) Program: A program designed to improve the quality of maternal care, reduce maternal mortality, and ultimately strengthen systems for safer childbirth by providing healthcare financing, digital health tools, capacity building and community engagement for maternal health providers in Nigeria.  You can read Helium MSD’s Privacy Notice here.
    7. HeliumCoPilot: HeliumCoPilot is a cutting-edge Large Language Model (LLM) Artificial Intelligence (AI) chatbot/software application that leverages Retrieval Augmented Generation (RAG) to enhance accuracy, minimize errors and improve predictive analytics for healthcare practitioners’ decision-making.

    6.COOKIES AND TRACKING TECHNOLOGIES

    We use cookies/SDKs for session management, analytics, security, and experience. Where required, We seek consent and honor regional choices. You can manage non-essential cookies via our banner and your browser/app settings. See Our Cookies and Tracking Technologies Notice for details.

    7.LAWFUL BASES FOR PROCESSING

    We process your data under one or more of the following lawful bases:

    • Legitimate Interest – where necessary for Our business operations, provided your rights are not overridden.
    • Consent – where you have given explicit consent for a specific purpose.
    • ContractContract-necessary to perform a contract with you or take steps at your request before entering into one.
    • Public Health – to support initiatives aimed at protecting and promoting public health.
    • Legal Obligation – where processing is required to comply with applicable law.

    8.PURPOSES OF PROCESSING YOUR DATA

    We may process your data (including, but not limited to, your personal data, anonymized data, pseudonymised data, and any other variations or forms of your data) for any or all of the following purposes:

    Purpose of ProcessingLawful Bases
    To help Us develop, improve, customise, or restructure   Our products and ServicesTo inform you whenever there are changes to Our terms of business or ServicesTo take statistical data and analytics for Our internal useCollecting, analysing, sharing, and additional processing of your data for statistical purposes, market insights, and internal or external reportingTo support 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:sending you marketing or promotional communications about Helium Health’s  products, services, and other offerings;generating marketing and data-driven insights;marketing enhancement of Helium Health’s products or services;purposes related to Helium Health’s  legitimate interests;statistical purposes, market research and analytics;supporting Helium Health’s business interests, legitimate interests, and other interestsTo analyse website usage and provide, maintain, and improve the content and functionality of the WebsiteLegitimate interest, Consent      
    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:research, studies, or other initiatives;the overall advancement of healthcare in Africa and the rest of the worldPublic Health
    To promote Our product and services by gathering and analysing survey responses, insights and testimonialsTo install non-strictly necessary cookies on Your deviceConsent
    To secure your data and prevent fraudLegitimate interest, legal obligation


    These purposes represent the lawful and limited ways data may be used. Most relate to providing healthcare and maintaining system integrity.

    9. HOW WE USE DE-IDENTIFIED/ANONYMIZED DATA

    As an integral function of the Platform, We process Health Information to create de-identified or anonymized data in accordance with NDPA, 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.

    10.YOUR RIGHTS

    As a data subject, you may have the following rights (subject to applicable law):

    • Access your personal data.
    • Request correction of inaccurate or incomplete data.
    • Request erasure (“right to be forgotten”).
    • Restrict or object to processing, including for marketing purposes.
    • Request data portability.
    • Withdraw consent at any time.
    • Object to automated decision-making or profiling.
    • Lodge a complaint with a regulatory authority.

    You may exercise your rights by contacting us at dpco@heliumhealth.com.

    11.DATA SHARING

    We may share your data with third parties depending on which of Our products you wish to use. To find out who We share your data with and why, please read the privacy notice for that specific product. When using Our Website, We share your data with the following third parties:

    Third PartiesPurpose 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
    MoEngageWe use MoEngage to gain insights and monitor user engagement on the Website. Read their privacy policy here
    PosthogWe use Posthog to analyse user engagement, facilitate session replays, and develop surveys on the Website. Read their privacy policy here
    SentryWe use Sentry to monitor, identify, debug, and resolve errors on the Website. Read their privacy policy here
    Amazon Web Service (AWS)We use AWS to enable cloud storage on Our Website. Read their privacy notice here
    Google Cloud Platform (GCP)We use Google Cloud Platform (GCP) to enable cloud computation on the Website. Read their privacy notice here
    FivetranWe use Fivetran to move data from various sources. Read their privacy notice here
    MailPoetWe use MailPoet to create, manage, and send our email marketing campaigns and newsletters to customers. 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 in order 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
    External CollaboratorsDepending on the product you use, We may occasionally share de-identified data with third-party collaborators for research or business purposes. In doing so, We ensure that all necessary security measures are in place to fully protect your privacy, so that you cannot be identified
    Collaborative PartnersWe collaborate with other businesses to support Our legitimate business objectives and may share your data with these partners to achieve these objectives


    12.RETENTION OF DATA

    We retain personal data for as long as necessary for the purposes outlined in this Privacy Notice, in line with legal requirements. Data may be retained longer where legally required, even if you request deletion. Marketing data will be deleted once you unsubscribe. We retain personal data only as long as necessary for the purposes collected, to provide services, and to satisfy legal/clinical retention obligations. De-identified/anonymized data may be retained indefinitely.

    Data is held only as long as necessary to meet care, legal, or regulatory requirements. Once anonymized, information can be retained without personal risk.

    13. SECURITY OF YOUR DATA

    We implement technical and organisational safeguards to protect your data against loss, misuse, or unauthorised access. While no system is entirely secure, We will promptly notify you and relevant authorities in the event of a significant breach.

    14.INTERNATIONAL DATA TRANSFERS

    Where data is transferred outside your country of residence, We ensure appropriate safeguards are in place, such as adequacy decisions, standard contractual clauses, or regulator approval. Safeguards such as Standard Contractual Clauses and adequacy decisions are applied so that data receives the same level of protection internationally as it does locally.

    15.MARKETING AND COMMUNICATIONS

    We only send you marketing communications with your consent. You may opt-out at any time via the unsubscribe link.

    16.COMPLAINTS

    For questions or complaints, please contact our Data Protection Officer (“DPO”) at dpco@heliumhealth.com. We will investigate and respond promptly.

    17.UPDATES TO THIS NOTICE

    We may update this Privacy Notice from time to time. Please check the “last updated” date when reviewing.

    18.CONTACT US

    If you have questions about this Notice or how we process your personal data, please contact our DPO via email at  dpco@heliumhealth.com.

    19. GOVERNANCE

    We operate a privacy program aligned to NDPA principles, with records of processing, DPIAs where required, vendor due diligence, training, and audits.

    Last Updated December 2025