Privacy Policy & Data Safety

Last Updated: September 27, 2024 • Version: 2.2

Summary for Aspire HMO Mobile App Users

This Privacy Policy applies to the Aspire HMO Mobile Application (available on the Google Play Store), the Aspire HMO website (aspirehmo.com), our enrollee web portal, and our offline healthcare coordination services. Aspire HMO is committed to safeguarding your confidential personal and medical information. We do not sell your personal or health data to advertisers or third parties.

1. Data Controller & Scope

This Privacy Policy governs the processing of personal and health data by Aspire Health Maintenance Organization Limited ("Aspire HMO", "we", "us", "our"), a registered health maintenance organization regulated by the National Health Insurance Authority (NHIA) of Nigeria, with its principal office at 3B Olumoroti Jaiyesimi Street, Gbagada Phase 2, Lagos, Nigeria.

This policy specifically covers:

The Aspire HMO Android Mobile Application distributed through the Google Play Store;
The official website at aspirehmo.com and associated enrollee, corporate, and provider portals;
Communications, customer care services, claim reimbursements, and care authorizations facilitated by Aspire HMO.

2. Categories of Information We Collect

In order to provide health insurance coverage, verify member eligibility at hospitals, and administer claims, we collect the following categories of data:

Data Category	Specific Data Elements	Collection Method
Personal Identification Data	Full name, date of birth, gender, residential address, email address, telephone number, profile photo, National Identification Number (NIN) where required for statutory verification, next-of-kin details.	Directly provided by you or your employer during plan enrollment and profile creation.
Health & Medical Data (Sensitive)	Medical history, reported symptoms, doctor consultations, diagnoses, hospital admissions, surgical records, prescription details, laboratory/diagnostic test results, and claims history.	Submitted by you for pre-authorization or provided by accredited healthcare providers in our network.
Financial & Billing Data	Premium payment records, transaction reference IDs, plan tier, billing dates, and bank account numbers (strictly used to disburse approved claim reimbursements to you).	Directly provided by you during premium payment or reimbursement claims submission.
Device & Technical Information	Device manufacturer and model, Android OS version, unique device identifiers (e.g. Android ID), IP address, network carrier, app version, crash diagnostic logs.	Automatically collected by the mobile app during active use and error events.
Approximate or Precise Location	GPS location or network-derived coordinates collected only when actively searching for nearby accredited healthcare providers.	Collected via device location services upon your explicit permission.

3. Sensitive Health & Medical Data Safeguards

Health and medical data are categorized as Sensitive Personal Data under the Nigeria Data Protection Act (NDPA) 2023 and medical ethics guidelines. We apply heightened technical and organizational safeguards to medical records:

Health data is collected strictly for medical necessity: evaluating plan eligibility, granting pre-authorization for treatments, adjudicating claims, and coordinating clinical care.
Access to health records is restricted to certified clinical officers, medical claims adjudicators, and treating healthcare providers on a strict "need-to-know" basis.
We never use, share, or disclose personal health information for commercial advertising, marketing campaigns, or profiling.

4. Android Device Permissions & Hardware Access

To deliver core features through our Google Play Store app, the Aspire HMO Android application may request the following device permissions. Every permission is tied directly to user-facing functionality and can be revoked at any time via your device settings (Settings > Apps > Aspire HMO > Permissions):

Android Permission	Purpose & Justification	Is it Required?
`ACCESS_FINE_LOCATION` `ACCESS_COARSE_LOCATION`	Locating Nearby Healthcare Facilities: Used while using the hospital finder to display accredited hospitals, pharmacies, eye clinics, and diagnostic labs near your current physical location and offer emergency navigation. Location data is never tracked in the background or sold.	Optional. You can manually enter a city or address instead.
`CAMERA`	Document & Prescription Capture: Allows you to snap clear photos of physical doctor prescriptions, pharmacy receipts, hospital bills, referral notes, and capture an optional profile avatar photo for your digital HMO card.	Optional. Required only when taking new photos directly inside the app.
`READ_MEDIA_IMAGES` `READ_EXTERNAL_STORAGE`	Document Uploads: Allows you to attach existing PDF or image files of hospital invoices and medical reports stored on your device when filing reimbursement claims.	Optional. Required only when uploading files from your local storage.
`POST_NOTIFICATIONS`	Critical Healthcare Updates: Sends push notifications regarding pre-authorization code issuance, claim status updates, plan renewal dates, and emergency alerts.	Optional. You may disable notifications and check updates manually.

5. How We Use Your Data (Purposes of Processing)

We process personal and health information solely for legitimate operational and healthcare purposes:

Administering Health Insurance Coverage: Enrolling members, verifying policy status, issuing digital HMO identity cards, and managing coverage tiers.
Facilitating Medical Care & Pre-authorization: Verifying eligibility at accredited hospitals and issuing pre-authorization codes for secondary and tertiary medical treatments.
Processing Claims & Reimbursements: Validating provider and enrollee claims, preventing fraudulent billing, and processing direct bank reimbursements.
Customer & Enrollee Support: Responding to inquiries, resolving billing discrepancies, and providing 24/7 emergency contact support.
Regulatory Compliance: Fulfilling mandatory reporting obligations under the National Health Insurance Authority (NHIA) Act 2022 and complying with statutory audit laws.
Application Performance & Security: Diagnosing app crashes, testing system stability, securing our infrastructure, and preventing unauthorized access.

6. Data Sharing & Third-Party Disclosure

Aspire HMO only shares personal data with third parties under strict confidentiality, regulatory oversight, and data protection agreements:

Accredited Healthcare Providers: We share member details and authorization statuses with hospitals, clinics, laboratories, and pharmacies in our accredited network to ensure you receive seamless care.
Certified Payment Gateways: When you pay premiums online, payments are securely processed by PCI-DSS Level 1 certified processors (such as Paystack or Flutterwave). Aspire HMO does not store your full credit/debit card numbers or security CVVs.
Cloud & Infrastructure Providers: Our servers and encrypted databases are hosted on enterprise-grade, secure cloud hosting platforms that comply with ISO 27001 and NDPA security standards.
Statutory & Regulatory Authorities: We may disclose data when legally required by the National Health Insurance Authority (NHIA), the Nigeria Data Protection Commission (NDPC), or in response to a valid court order.

7. Commitment: No Sale of Personal or Health Data

Our Explicit Guarantee

Aspire HMO does not sell, rent, monetize, or trade your personal, medical, or device data to any third party. We do not disclose user data to data brokers, ad networks, or telemarketers. We do not use your health data or device permissions for behavioral advertising.

8. Data Security & Encryption Standards

We deploy robust administrative, technical, and physical security measures to safeguard your information against unauthorized access, alteration, disclosure, or destruction:

Encryption in Transit: All communication between the Aspire HMO Android App, our web portals, and back-end servers is encrypted using modern Transport Layer Security (TLS 1.3 / HTTPS).
Encryption at Rest: Sensitive medical records, personal identifiers, and credentials stored in our databases are protected with industry-standard AES-256 encryption.
Role-Based Access Controls: Only authenticated and vetted personnel with specific medical or administrative authorization can view enrollee health records.
Audit Logging & Monitoring: We maintain immutable audit logs of access to sensitive patient information to detect and prevent unauthorized data views.

9. Data Retention & Archival

We retain personal and health data only for as long as necessary to fulfill the purposes outlined in this policy or as required by applicable laws:

Active Enrollee Profile Data: Retained for the duration of your active policy coverage and account registration.
Medical Claims & Clinical Records: In compliance with National Health Insurance Authority (NHIA) statutory requirements and Nigerian medical record retention regulations, medical claims, diagnostic records, and pre-authorizations are securely archived for a mandatory statutory period (typically six to seven years) after claim settlement.
Transient Technical & Crash Logs: Server telemetry, crash reports, and operational debug logs are automatically purged or anonymized within 90 to 180 days.

10. User Account & Data Deletion (Google Play Store Mandate)

In accordance with Google Play's User Data & Account Deletion Policy, enrollees and registered users have the right to delete their Aspire HMO account and associated personal data at any time. We provide two simple ways to exercise this right:

Option A: Delete Account Directly Inside the Android App

Open the Aspire HMO Mobile App on your Android device.
Log into your account and tap on Profile / More (bottom navigation).
Select Settings & Security.
Tap Delete Account at the bottom of the screen.
Read the confirmation notice and tap Confirm Account Deletion. Your account will be immediately deactivated and scheduled for permanent data erasure.

Option B: Request Deletion via Web / Email (Without Reinstalling App)

If you have uninstalled the app or prefer to submit a web-based request, you can request account and data deletion through either of the following channels:

Email Request: Send an email from your registered email address to privacy@aspirehmo.com with the subject line: Account and Data Deletion Request - [Your Enrollee ID or Phone Number].
Online Contact Form: Visit our Contact Page, select "Account & Privacy", and submit your deletion request.

What Happens When You Delete Your Account:

Permanently Deleted: Your login credentials, user profile, saved addresses, contact details, push notification tokens, and marketing preferences are permanently erased from our active systems within 7 business days of verification.
Statutory Retention Exceptions: As permitted under Google Play policy and mandated by Nigerian healthcare and financial regulations, past medical claims history, pre-authorization codes, and financial accounting transactions cannot be immediately destroyed. Such data is permanently unlinked from your online account, de-identified where feasible, and retained in secure offline archives strictly for the statutory duration required by the NHIA and tax regulations.

11. Children's & Dependants Privacy

The Aspire HMO mobile application and services are intended for individuals who are at least 18 years old. We do not knowingly permit children under 13 to create independent accounts.

Minors and children may be enrolled as dependants under a Family, SME, or Corporate healthcare plan. When dependant information (such as name, date of birth, and health records) is processed, it is collected solely with the explicit consent of the primary policyholder (parent, legal guardian, or employer sponsor) to facilitate medical coverage for that child.

12. Your Legal Rights under the NDPA 2023

Under the Nigeria Data Protection Act (NDPA) 2023, you have enforceable rights regarding your personal data:

Right to Access: You may request a copy of the personal data Aspire HMO holds about you.
Right to Rectification: You may request correction of inaccurate, incomplete, or outdated personal information.
Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data, subject to statutory retention requirements.
Right to Restrict or Object to Processing: You may object to or request restrictions on the processing of your data in specific circumstances.
Right to Data Portability: You may request to receive your personal data in a structured, commonly used, machine-readable format.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our Data Protection Officer at privacy@aspirehmo.com. We respond to all verified requests within 30 days at no cost to you.

13. Telemetry, Crash Analytics & Cookies

Our mobile app and website use minimal, privacy-centric diagnostic tools to maintain reliability:

Crash Reporting: The Android app may collect anonymized stack traces and hardware states via Google Play Vitals or crash diagnostic tools strictly to fix bugs and improve stability.
No Third-Party Ad Trackers: We do not include third-party ad tracking SDKs, commercial beacons, or spyware in our mobile application.
Web Cookies: Our website uses essential session cookies to remember your preferences and maintain authenticated sessions. You can configure your browser to reject cookies, though some portal features may be impacted.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our app features, healthcare regulations, or Google Play Developer Policies. When updates are published, the "Last Updated" date at the top of this page will be revised.

For material changes that affect your rights or the way we handle health data, we will provide prominent notice via a push notification in the Aspire HMO app, an email to your registered address, or a notice on our website prior to the change taking effect.

15. Contact Us & Data Protection Officer (DPO)

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal health information, or our Google Play Store data safety practices, please contact us:

Data Controller: Aspire Health Maintenance Organization Limited
Data Protection Officer (DPO): privacy@aspirehmo.com
General Customer Care: info@aspirehmo.com
Telephone Support: +234 802 131 0634 • +234 906 119 7867
Physical Address: 3B Olumoroti Jaiyesimi Street, Gbagada Phase 2, Lagos, Nigeria.
Supervisory Authority: Nigeria Data Protection Commission (NDPC) • ndpc.gov.ng