Privacy Policy

Effective date: July 1, 2023

At Zagodu Health Limited (“Zagodu Health,” “we,” or “us”), we are committed to protecting your privacy, and we take great care with your personal information that we gather when you access or use Zagoduhealth.com and related websites, applications, and services owned and operated by Zagodu Health and that link to this Privacy Policy (collectively, the “Services”). This Privacy Policy is meant to help those that use our Services to explore providers or book appointments (“Users”) and doctors, dentists, or other healthcare specialists, professionals, providers, organizations or agents, or affiliates thereof that use our marketing services (“Healthcare Providers,” and collectively with Users, “you,” or “your”) understand how we treat your personal information.BY USING OR ACCESSING THE SERVICES IN ANY MANNER, YOU ACKNOWLEDGE THAT YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION IN THE FOLLOWING WAYS. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU MAY NOT USE THE SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF. Any use of Zagodu Health’s Services is at all times subject to the Agreement (as the term “Agreement” is defined in our Terms of use, which incorporates this Privacy Policy).

HIPAA and PHI

Certain demographic, health and/or health-related information that Zagodu Health collects about Users as part of providing the Services to our Healthcare Providers may be “protected health information” or “PHI” and governed by the Health Insurance Portability and Accountability Act and its implementing regulations (“HIPAA”). Specifically, when (i) Zagodu Health is providing administrative, operational, and other services to a Health Care Provider and this Healthcare Provider is a “Covered Entity” (as such term is defined in HIPAA); and (ii) in order to provide those services, Zagodu Health receives identifiable information about a User on behalf of the Healthcare Provider, Zagodu Health is acting as a “Business Associate” (as such term is defined in HIPAA) of the Health Care Provider, and this identifiable information is regulated as PHI.

HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. Please read the Notice of Privacy Practices of your Health Provider to understand how your PHI can be used and disclosed. HIPAA does not apply to Personal Data (defined below) that is not PHI. Personal data that a User provides to Zagodu Health when Zagodu Health is not acting as a Business Associate is not PHI. To provide just a few examples, when you (i) create an account, (ii) search for Healthcare Providers or available appointments with Healthcare Providers, (iii) complete general medical history forms that are not required by or provided by a particular Healthcare Provider (“General Medical History Forms”), (iv) post reviews, or (v) provide device/IP Information or Web Analytics information by browsing our websites (see below).

Personal Data

The following subsections detail the categories of Personal Data that we collect. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. For each category of Personal Data, these subsections also set out the source of that Personal Data, our commercial or business purpose for collecting that Personal Data, and the categories of third parties with whom we share that Personal Data. More information regarding those sources and categories are set forth below.

User Personal Data

THE FOLLOWING SUBSECTIONS APPLY ONLY TO USERS. IF YOU ARE A HEALTHCARE PROVIDER, PLEASE SEE THE HEALTHCARE PROVIDER PERSONAL DATA SECTION BELOW.

Categories of Personal Data We Collect

Categories of Sources of Personal Data

Commercial or Business Purposes for Collecting Data

• Providing, Customizing, and Improving the Services
  • Creating and managing your account or other user profiles.
  • Billing our healthcare provider clients.
  • Providing you with the products, services, and information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics, and product development.
  • Personalizing the Services, website content, and communications based on your preferences.
  • Fraud protection, security, and debugging.
• Marketing the Services
  • Marketing and selling the Services.
  • Showing you advertisements, including interest-based or online behavioral advertising.
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, including to remind you of an upcoming appointment, and sending you information about Zagodu Health or the Services.
  • Sending emails and other communications that display content that we think will interest you and according to your preferences including notifying you about certain resources, Healthcare Providers or Services.
• Legal Requirements
  • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, Zagodu Health or another party.
  • Enforcing any agreements with you.
  • Responding to claims that any posting or other content violates third-party rights.
  • Resolving disputes.

How We Share Your Personal Data

In certain circumstances, we may share your Personal Data with the following categories of service providers and other third parties for the indicated business purposes:

Healthcare Provider Personal Data

THE FOLLOWING SUBSECTIONS APPLY ONLY TO HEALTHCARE PROVIDERS. IF YOU ARE A USER, PLEASE SEE THE USER PERSONAL DATA SECTION ABOVE.

Categories of Personal Data We Collect

Categories of Sources of Personal Data

Commercial or Business Purposes for Collecting Data

• Providing, Customizing, and Improving the Services
  • Creating and managing your account or other user profile.
  • Producing invoices and billing statements for our clients.
  • Providing you with the products, services, and information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics, and product development.
  • Personalizing the Services, website content, and communications based on your preferences.
  • Fraud protection, security, and debugging.
• Marketing the Services
  • Marketing and selling the Services.
  • Showing you advertisements, including interest-based or online behavioral advertising.
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, including to remind you of an upcoming appointment, and sending you information about Zagodu Health or the Services.
  • Sending emails and other communications that display content that we think will interest you and according to your preferences including notifying you about certain resources, Healthcare Providers, or services.
• Legal Requirements
  • Fulfilling our legal obligations under applicable law, regulation, court order, or other legal processes, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property, or safety of you, Zagodu Health, or another party.
  • Enforcing any agreements with you.
  • Responding to claims that any posting or other content violates third-party rights.
  • Resolving disputes.
• Onboarding Verification
  • Confirming providers have the necessary credentials to practice in the state where advertised.

How We Disclose Your Personal Data

In certain circumstances, we may disclose your Personal Data to the following categories of service providers and other third parties for the indicated business purposes:

THE FOLLOWING SECTIONS APPLY TO ONLY TO USERS.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” sections above.

Business Transfers

All Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated and/or de-identified data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build, and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Advertising, and Opt-Out

The following sections provide additional information about how we collect your Personal Data.

Information Collected Automatically

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, mobile identifiers, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services. We do this to analyze trends, learn about and advertise to our user base, and operate and improve our Services. For example, we use Cookies to tailor the Services or customize advertisements by tracking navigation habits, measuring performance, storing authentication status so re-entering credentials is not required, customizing user experiences with the Services, and for analytics and fraud prevention. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required to provide you with features or services you have requested. For example, certain Cookies enable you to log into the secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services, how long visitors are viewing pages on the Services, mouse clicks, mouse movements, scrolling activity, and text typed into the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns to help us improve our campaigns and the content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of cookies by visiting the Google advertising opt-out pageor the Google Analytics Opt-out Browser Add-on page.
• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests to provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
• Web Beacons(e.g., clear GIFs or pixel tags) are tiny graphic image files embedded in a webpage or email that may be used to collect information about the use of our Services, the web services of selected advertisers, and the emails, special promotions, or newsletters that we send. The information collected by Web Beacons allows us to analyze how many people are using the Services, using selected publishers’ web services or opening emails, and for what purpose. Also, it allows us to enhance our interest-based advertising (discussed further below).
• Mobile Device Identifiers Mobile device identifiers help Zagodu Health learn more about our Users’ demographics and internet behaviors. Mobile device identifiers are data stored on mobile devices that may track mobile devices and data, activities occurring on and through it, and the applications installed on it. Mobile device identifiers enable the collection of Personal Data, such as media access control, address, location, and tracking data, including without limitation IP address, domain server, type of device(s) used to access the Services, web browser(s) used to access the Services, referring webpage or other source through which you accessed the Services, other statistics, and information associated with the interaction between your browser or device and the Services.
• Cross Device Matching. To determine if users have interacted with content across multiple devices and to match such devices, we may work with partners who analyze device activity data and/or rely on your information (including demographic, geographic, and interest-based data). We may also provide de-identified data to these partners to supplement this analysis. Based on this data, we may display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of Services across devices.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on your browser software) allowing you to decide on acceptance of each new Cookie in a variety of ways. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. You can also delete all Cookies that are already on your computer. Although you are not required to accept Zagodu Health’s Cookies, if you block, reject, or delete them, you may have to manually adjust some preferences every time you access the Services, as some functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find more information about Cookies, including how to manage and delete Cookies, please visit here.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Not all browsers offer a Do Not Track option, and there is currently no industry consensus as to what constitutes a Do Not Track signal. Please note that, for these reasons and because of our use of Cookies, our Services, like many website operators, do not support “Do Not Track” requests sent from a browser at this time.

Information about Interest-Based Advertisements

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you or derived or inferred from the online activity or usage patterns of particular users on the Services and/or services of third parties. Such information may include IP address, mobile device ID, operating system, browser, webpage interactions, geographic location, and demographic information, such as gender and age range. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including Web Beacons, from an ad network to you through the Services. Web Beacons allows ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. This information helps Zagodu Health learn more about our users’ demographics and internet behaviors. Web Beacons also enables ad networks to serve targeted advertisements to you when you visit other websites. Web Beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a webpage from their site.

Please note that even after opting out of Interest-Based Ads, you may still see Zagodu Health advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that Zagodu Health is no longer using tracking tools. Zagodu Health may still collect information about your use of the Services even after you have opted out of Interest-Based Ads and may still serve advertisements to you via the Services based on information collected via the Services.

Data Security

The security of your Personal Data is important to us. We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we process that data. We endeavor to follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and in storage. For example, the Services use industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data. We may store and process your information on servers local and abroad. We maintain what we consider industry-standard backup and archival systems. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanisms; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, for example, by making good faith efforts to store Personal Data in a secure operating environment that is not open to the public, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot and do not guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss, or inadvertent disclosure of your information or content.

If at any time during or after our relationship, we believe that the security of your Personal Data may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your e-mail address in your account up to date. You can update that e-mail address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification. Please include your address when you submit your request. You can make this election at any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Data.

Data Retention

We retain Personal Data about you as necessary to provide our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, provide our Services, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

• We retain your account information and credentials for as long as you have an account with us.
• We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively, and efficiently.
• We retain any protected health information (“PHI”) consistent with our obligations under our Business Associate Agreements with Covered Entities and HIPAA.

Children’s Privacy

The Services are not directed to or intended for use by children under 13 years of age. If you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. By accessing, using, and/or submitting information to or through the Services, you represent that you are over the age of 13. As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under the age of 13. If we learn that we have received any Personal Data directly from a child under age 13 without first receiving their parent’s verified consent, we will use that Personal Data only to respond directly to that child (or their parent or legal guardian) to inform the child that they cannot use the Services. We will then subsequently delete that child’s Personal Data. If you believe that a child under 13 may have provided us with Personal Data, please contact us at [email protected].

If you are between the age thirteen (13) and the age of majority in your place of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. If you are a parent or legal guardian of a minor child, you may, in compliance with the Agreement, use the Services on behalf of such minor child. Any information that you provide us while using the Services on behalf of your minor child will be treated as Personal Data as otherwise provided herein.

If you use the Services on behalf of another person, regardless of age, you agree that Zagodu Health may contact you for any communication made in connection with providing the Services or any legally required communications. You further agree to forward or share any such communication with any person for whom you are using the Services on behalf.

How We Use Information That is Neither Personal Data nor PHI

Certain information that Zagodu Health collects may be neither Personal Data nor PHI, including information that does not include any identifiable information at collection or which we have de-identified and/or aggregated from Personal Data or PHI. We may use this information for any purpose permitted by applicable law, including but not limited to purposes of better understanding who uses Zagodu Health and how we can deliver a better digital healthcare experience.

Controlling Your Personal Data & Notifications

If you are a registered user of the Services, you can modify certain Personal Data or account information by logging in and accessing your account. If you wish to close your account, please e-mail us at [email protected]. Zagodu Health will use reasonable efforts to delete your account as soon as reasonably possible. Please note, however, that Zagodu Health reserves the right to retain information from closed accounts consistent with our internal data retention policies and procedures.

You must promptly notify us if any of your account data is lost, stolen, or used without permission.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months, including the following:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each third-party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data purchased by third-party recipients.

Deletion

You have the right to request that we delete the Personal Data that we have collected from you. This right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. This right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Personal Data Sharing or Selling

We may shared and sell the foregoing categories of Personal Data for the purposes of cross-contextual behavioral advertising:

• Demographic data
• Web analytics or other similar network activity information

As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Sharing your data through third-party Cookies for online advertising may be considered a “sale” of information. You can opt out of data selling and/or sharing by following the instructions in this section.

We share Personal Data with the following categories of third parties:

• Advertising partners

Over the past 12 months, we have shared your Personal Data with the categories of third parties listed above for the following purposes:

• Marketing and advertising the Services.
• Showing you advertisements, including interest-based or online behavioral advertising.

Once you have submitted an opt-out request, we will not ask you to reauthorize the sharing of your Personal Data for at least 12 months. To our knowledge, we do not share the Personal Data of minors under 16 years of age.

Financial Incentives

At Zagodu Health, we value your data because it allows us to better understand your goals and preferences and improve our products and services to better serve you. From time to time, we may offer a financial incentive for your participation in our user research. The financial incentive we offer is based on our determination of the estimated value of your data. If you participate in the research, you may be asked to submit personal information in surveys, forms, or through your account. The personal information you submit in connection with this research will only be used internally to improve our product; we will never share or sell this data to third parties.

Through your participation in the research, we may collect the following categories of personal information about you:

• Identifiers, such as your name, address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
• Characteristics of protected classifications
• Commercial information, such as products or services you’ve purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, such as your browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.
• Geolocation data.
• Audio, electronic, visual, thermal, olfactory, or similar information. For example, we may collect your voice recordings.
• Professional or employment-related information.
• Education information
• Any other personal information you may enter into a free-form field of our surveys or forms.
• Inferences drawn from any of the foregoing categories of personal information.

Participation in the financial incentive is entirely optional. If you participate in a financial incentive, you agree that we are not required to comply with your right to know or delete personal information collected in exchange for the financial incentive. If you are a participant in a financial incentive we offer, you may withdraw from the financial incentive at any time by emailing us at the email address provided to you with your individual notice of the financial incentive.

Exercising Your Rights

To exercise the rights as described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.

We will respond to your Valid Request within the applicable time period required by law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

To the extent rights are afforded to you, you may submit a Valid Request using the following method:

• You can email us at [email protected]

Changes to this Privacy Policy

We reserve the right to amend our Privacy Policy at our discretion and at any time. When we make changes to the Privacy Policy, we will notify you by email or through a notice on our website homepage. Use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, your choices, and rights regarding such use, please do not hesitate to contact us at:

• E-mail: [email protected]