Important: Because this is a healthcare application, the final policy should be reviewed against Greenbay HMO’s actual data practices and applicable Nigerian privacy requirements before publication. In particular, the Nigeria Data Protection Act (NDPA) and Google Play’s current health-app requirements should be considered.
Greenbay HMO ("Greenbay HMO," "we," "us," or "our") is committed to protecting the privacy and security of the personal information of users of the Greenbay HMO mobile application (the "App").
This Privacy Policy explains how we collect, use, disclose, store, and protect information when you download, access, or use the App.
By using the App, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the App.
1. ABOUT GREENBAY HMO
Greenbay HMO provides Health Maintenance Organisation (HMO) services and related healthcare management services. Through the App, users may be able to access information and services relating to their healthcare plan, healthcare providers, authorisations, claims, appointments, communications, and other services made available by Greenbay HMO.
2. INFORMATION WE COLLECT
Depending on how you use the App, we may collect the following categories of information:
We may collect information that identifies or relates to you, including:
Full name
Date of birth
Gender
Phone number
Email address
Residential or contact address
Identification information
HMO membership or enrolment information
Policy or membership number
Employer or organisation information, where applicable
Emergency contact information
Login credentials and authentication information
Because Greenbay HMO provides healthcare-related services, the App may process health-related information necessary to provide those services. Depending on the features you use, this may include:
Medical history
Diagnosis and treatment information
Healthcare provider information
Healthcare service requests
Prescription or medication information
Laboratory or diagnostic information
Medical bills and claims information
Authorisation requests
Appointment information
Other health information provided by you or your healthcare providers
Health and medical information is treated as sensitive information and is processed only where necessary and in accordance with applicable laws.
When you use the App, we may automatically collect certain technical information, such as:
Mobile device type and model
Operating system and version
App version
Unique device or application identifiers
IP address
Mobile network information
Crash reports and diagnostic information
Log information
Information about how you interact with the App
Where a feature requires it and you give the necessary permission, the App may access location information to provide location-based services, such as helping you identify healthcare providers or facilities near you.
We will not collect precise location information unless it is necessary for a specific feature and permitted by your device settings and applicable law.
We may collect information that you voluntarily provide when you:
Create or update an account
Complete your profile
Submit healthcare requests
Contact customer support
Submit claims or supporting documents
Search for or select healthcare providers
Make enquiries
Participate in surveys or feedback activities
Communicate with Greenbay HMO through the App
3. HOW WE USE YOUR INFORMATION
We may use the information we collect for legitimate business and healthcare-related purposes, including to:
Create and manage your Greenbay HMO account
Verify your identity and membership status
Provide HMO and healthcare management services
Provide access to healthcare providers and facilities
Process healthcare requests and authorisations
Process and manage claims
Facilitate appointments and healthcare services
Communicate with you regarding your membership or healthcare services
Respond to enquiries and provide customer support
Send service-related notifications and communications
Maintain and improve the App
Detect, prevent, and investigate fraud, abuse, security incidents, and unauthorised activity
Maintain the security and integrity of our systems
Comply with applicable legal, regulatory, and contractual obligations
Conduct internal reporting, auditing, analytics, and service improvement
Protect the rights, property, safety, and security of Greenbay HMO, our users, healthcare providers, and other relevant parties
We will not use your personal information for purposes that are incompatible with the purpose for which it was collected unless permitted or required by applicable law.
4. LEGAL BASIS FOR PROCESSING
Where required by applicable data protection law, Greenbay HMO will process personal information on an appropriate legal basis.
Depending on the circumstances, this may include:
Your consent
Performance of a contract or provision of healthcare/HMO services
Compliance with a legal or regulatory obligation
Protection of vital interests
Legitimate interests, where permitted by law
Other lawful bases recognised under applicable data protection legislation
Where processing is based on consent, you may have the right to withdraw your consent, subject to applicable legal or contractual limitations.
5. HOW WE SHARE YOUR INFORMATION
We do not sell your personal information.
We may share personal information where necessary and lawful with:
Healthcare Providers
We may share relevant information with hospitals, clinics, pharmacies, laboratories, doctors, and other healthcare providers to facilitate healthcare services and manage your HMO benefits.
Service Providers
We may engage trusted third-party service providers to assist with services such as:
Cloud hosting and data storage
Application development and maintenance
Customer support
Communication and messaging
Authentication and security
Analytics and diagnostics
Payment processing, where applicable
These service providers may only process information as necessary to provide services to us and subject to appropriate contractual and security safeguards.
Employers or Scheme Sponsors
Where your HMO membership is provided through an employer, organisation, or other scheme sponsor, we may share information with them where necessary for administration of the relevant healthcare scheme and as permitted by applicable law.
We will take reasonable steps to limit the information shared to what is necessary and appropriate.
Regulators and Public Authorities
We may disclose information where required or permitted by law, regulation, court order, or a lawful request from a competent government or regulatory authority.
Professional Advisers
Where necessary, we may disclose information to professional advisers, auditors, insurers, legal advisers, or other authorised parties for legitimate business, legal, compliance, or risk-management purposes.
6. INTERNATIONAL DATA TRANSFERS
Some of our technology or service providers may process or store information outside Nigeria.
Where personal information is transferred outside Nigeria, Greenbay HMO will take appropriate measures required by applicable data protection law to ensure that your information receives an adequate level of protection.
7. DATA SECURITY
Greenbay HMO takes reasonable technical and organisational measures to protect personal information against:
Unauthorised access
Unauthorised disclosure
Loss
Misuse
Alteration
Destruction
Other unlawful or accidental processing
Security measures may include access controls, authentication mechanisms, encryption where appropriate, monitoring, secure infrastructure, and other safeguards.
However, no electronic transmission or storage system can be guaranteed to be completely secure. You are responsible for keeping your account credentials and device secure and should notify us promptly if you believe your account has been compromised.
8. DATA RETENTION
We retain personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, provide our services, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and protect our legitimate interests.
The retention period may vary depending on the type of information and the applicable legal or regulatory requirements.
When personal information is no longer required, we will take reasonable steps to securely delete, anonymise, or otherwise dispose of it in accordance with our retention policies and applicable law.
9. YOUR DATA PROTECTION RIGHTS
Subject to applicable law, you may have rights in relation to your personal information, including the right to:
Request access to personal information we hold about you
Request correction of inaccurate or incomplete information
Request deletion of your personal information in appropriate circumstances
Request restriction of certain processing
Object to certain processing
Request portability of certain personal information, where applicable
Withdraw consent where processing is based on consent
Lodge a complaint with the relevant data protection authority
Some rights may be subject to legal, regulatory, contractual, or other limitations.
To exercise your rights, please contact us using the details provided in the Contact Us section below.
The App is not intended to be used independently by children where applicable law requires parental or guardian involvement.
Where Greenbay HMO provides healthcare services to minors through a parent, guardian, employer-sponsored scheme, or other lawful arrangement, we will process the minor's information in accordance with applicable data protection and healthcare laws.
If you believe that a child has provided personal information to us unlawfully or without appropriate authorisation, please contact us so that we can investigate and take appropriate action.
The App may use technologies such as cookies, software development kits (SDKs), local storage, log files, or similar technologies to support functionality, security, analytics, performance monitoring, and service improvement.
Where applicable, you may be able to control certain permissions or settings through your device or App settings.
The App may contain links to third-party websites, applications, healthcare providers, or other services.
Greenbay HMO is not responsible for the privacy practices, content, or security of third-party services that we do not control.
We encourage you to review the privacy policies of third-party services before providing them with your personal information.
With your permission, the App may send push notifications relating to your account, healthcare services, claims, authorisations, appointments, service updates, security alerts, and other relevant communications.
You may manage push notification permissions through your device settings. Disabling notifications may affect certain App functionality or your ability to receive timely service-related information.
If you wish to close your Greenbay HMO account or request deletion of personal information associated with your account, you may contact Greenbay HMO using the contact details below.
Certain information may need to be retained where required by law, regulation, healthcare requirements, contractual obligations, fraud prevention requirements, or other lawful purposes.
Where deletion is not possible or is subject to an exception, we will explain the applicable limitation where required by law.
We may update this Privacy Policy from time to time to reflect changes to our services, technology, legal requirements, or data processing practices.
When we make material changes, we may notify you through the App, our website, email, or other appropriate means.
The updated Privacy Policy will include a revised "Last Updated" date. Your continued use of the App after an updated Privacy Policy becomes effective constitutes acknowledgement of the updated policy, subject to applicable law.
If you have questions, concerns, complaints, or requests regarding this Privacy Policy or the way Greenbay HMO handles your personal information, please contact us:
Greenbay HMO