NDPR Statement

Our commitment

Global Well BHSC processes personal data in accordance with the Nigeria Data Protection Regulation (NDPR) 2019, the Nigeria Data Protection Act (NDPA) 2023, and directives issued by the Nigeria Data Protection Commission (NDPC).

Principles we follow

• Lawfulness, fairness, and transparency in every processing activity.
• Purpose limitation — data is collected for specific, explicit, and legitimate purposes.
• Data minimisation — we collect only what is necessary for the stated purpose.
• Accuracy — we take reasonable steps to keep personal data accurate and up to date.
• Storage limitation — retention periods are defined per contract and per law.
• Integrity and confidentiality — appropriate technical and organisational safeguards.
• Accountability — documented policies, DPIA where applicable, and audit trails.

Lawful basis

We rely on your consent, the performance of a contract, our legitimate interests, and compliance with legal obligations as the lawful basis for processing personal data.

Data subject rights

As a data subject in Nigeria, you have the right to be informed, to access, to correct, to object, to withdraw consent, to restrict processing, to request deletion (subject to applicable exceptions), and to data portability. To exercise any of these rights, contact our data protection point at hello@globalwellbhsc.com.

Cross-border transfers

Where we transfer personal data outside Nigeria — including to service providers or collaborators in the United States — we do so under contractual safeguards consistent with NDPR requirements and NDPC guidance.

Security safeguards

• Encryption in transit (TLS 1.2+) and encryption at rest where feasible.
• Role-based access, least-privilege principles, and audit logging.
• Vetted subprocessors under written data-processing agreements.
• Documented incident-response and breach-notification procedures.

Breach notification

In the event of a personal-data breach that is likely to result in risk to data subjects, we will notify the Nigeria Data Protection Commission and affected data subjects within the timeframes required by the NDPA 2023.

Complaints

If you believe your rights have been infringed, you may contact us first at hello@globalwellbhsc.com. You also have the right to lodge a complaint with the Nigeria Data Protection Commission.

Related policies

See our Privacy Policy and HIPAA statement for related detail on how we handle personal and health information across jurisdictions.