Throughout this Privacy Policy, “Bastion”, “we”, “us” or “our” refers to Bastion Health Limited. Further, for purposes of this Privacy Policy, “Website” includes our bastionhmo.com, its subdomains and any mobile applications owned by Bastion. 

This Policy describes how medical and/or other information about you may be used and disclosed and how you can get access to this information. 

Introduction

• At Bastion, we value the trust you have placed in us and intend to continue to earn your trust each day. Protecting the privacy of your personal information is a major priority throughout all of our business practices and procedures. Our commitment to protecting your privacy is reflected in this Privacy Policy, which describes our policies in using, gathering, communicating, and protecting information about you. Our procedures and policies protecting and safeguarding your personal information are maintained both while you are insured under a policy we administer and for any time thereafter.

Personal Information We Collect: 

• We receive information from you on applications for insurance and related forms. We also receive information from outside sources, including eligibility listings from employers or schools (as applicable) and providers of administrative services. This information may include, amongst other things:
  • Contact Information (e.g., name, phone number, address, and email address);
  • Date of Birth; marital status and your dependents
  • Financial information(e.g., bank account, debit and credit card account numbers, balances and information related to payment for healthcare services), and (as applicable) your academic enrollment status or employment details;
  • Government identification numbers (e.g., Driver’s License Number, National Voter’s Card Number, National Identification Number);
  • Benefits coverage information and Health Information (e.g., health insurance status and information related to healthcare services received from healthcare providers);
  • Geo-Location and other demographic information;
• In connection with your use of our Website, we may collect the following information:
  • Your Internet Protocol (IP) address;
  • The e-mail addresses of users who communicate with us;
  • Aggregate information on what pages on our Website users’ access or visit;
  • Login Information;
  • Information volunteered by the user, such as site registration and email update requests;
  • Information necessary to complete transactions with us.
• We receive information from you and others regarding premium payments and reimbursements. This information may include, among other things, your ATM card numbers, bank account numbers, and other material relating to payments to/from you;
• We receive information about you in connection with health coverage claims from third parties providing benefits and services under your coverage, including providers of medical services and claims administrators. This information may include, among other things, medical services bills and medical record information.

We retain personal information only so long as required by our business practices or by applicable law. 

Personal Information We Disclose:

• We do not disclose any non-public information about you to anyone, except as authorized or as permitted or required by law. We do not sell or otherwise disclose your personal information to anyone for purposes unrelated to our products and services.
• We may disclose your personal information to underwrite your health insurance coverage, process and record your premium payments, communicate your eligibility for benefits as provided in the policies, protect you against fraud, and service your health insurance claims. For instance, we may provide insurance companies, medical healthcare providers, thirdparty claims administrators, and employers or schools (as applicable) with information confirming that insurance premium has been received, paying for insurance coverage during a specific period of time, and with information confirming that specified medical services were provided and are eligible for payment;
• We use the personally identifiable information you voluntarily provide to register you as a user of the Website or to complete transactions with us at your request. We will not use your information for any purpose that you have not expressly authorized. Your information is not sold, rented, or shared with other entities or organizations for commercial purposes or in ways different than what is disclosed in this Privacy Policy;
• From time to time, we may disclose information to fulfill certain legal and regulatory requirements or if we believe, in good faith, that such disclosure is legally required or necessary to protect others’ rights or to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We may also provide information to a court, government agency, or other third parties when subpoenaed or as otherwise required by law. Further, in the event Bastion is subject to a merger or acquisition, we may provide information to the new owners of the business. Disclosure may also be required for company audits or to investigate a complaint or security threat.

Confidentiality and Security of Personal Information

• We restrict access to information about you to those employees and third parties who need to know that information in order to provide the benefits and services pertinent to your insurance policy. All personal information exchanged with third parties (such as health care providers, insurance companies, and entities administering claims) is restricted by confidentiality agreements. Our employees are trained and required to safeguard all such information. We maintain physical, electronic, and procedural safeguards that comply with federal and state regulations to protect information about you from disclosure. If at any time in the future, it is necessary to disclose any of your personal information in a manner that is inconsistent with this Policy, we will give you advance notice of the proposed change so that you will have the opportunity to consent or refuse consent to such disclosure;
• We will apply the policies discussed above in the event we propose to disclose your information to a third party. If we propose to disclose your information to a third party that is acting as our agent or on our behalf, we will ensure that the third party has agreed to assure adequate protection of your information.

Choice/Opting Out:

• You may choose to restrict our use of your information. You may exercise your choice to “opt out” of providing personal information in many ways. Page 4 of 6 When selecting to use certain services or features of our Website, you can choose whether to share personal information with respect to the particular service or feature. If you receive communications from us that you do not want to receive, you can opt-out from receiving these communications, by requesting that we remove your information from our database.
• You may also opt out entirely from providing personal information to us by not creating an account on our Website, or not completing transactions with us through the Website. You may also choose at a later date to have your name removed from our database. However, certain sections of our Website do require registration in order to use these sections and services. If you choose not to register or provide certain information, these sections will not be available for your use.
• We will not use your information for any purpose other than for those purposes you have authorized. Further, we will not use your information for a purpose that is incompatible with the purpose for which it was originally authorized by you.

Security

• Your user account containing your information is password protected. Only those who log on with your password can access your account. Our authorized personnel may also access your user account. Any transactions requiring you to enter personal identifying information are submitted via a secure, encrypted page. We have taken appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. However, please remember that you play a valuable part in security as well. Your password to access your account should never be shared with anyone. After you have finished using the Website, you should log off and exit your browser so no unauthorized persons can use our Website with your name and account information. Furthermore, if you provide any information to parties who operate websites that are linked to or from our Website, different rules may apply to their collection, use, or disclosure of your personal information. We encourage you to review the privacy policies of such other sites before revealing any sensitive or personal information. Despite precautions taken by you or by us, “perfect security” does not exist on the Internet. We cannot
• We make every effort to ensure that the information on the Website, as well as the information which you have provided to us, is reliable for the use you intend, and that it is accurate, complete and current. To assist us in ensuring that your information is relevant on an ongoing basis for its intended purposes, we encourage you to update your information on the Website as frequently as may be necessary.

Cookies

• Cookies are pieces of information that a website transfers to a user’s computer for purposes of storing information regarding the user’s preferences. Just as many major websites use cookies as a standard practice to provide useful information to a user, Bastion uses cookies to deliver website content specific to your identified interests and to guide you through your session on the Website. By themselves, cookies do not personally identify users, although they do identify a user’s computer. A user can opt not to take advantage of the cookie benefits by setting his or her browser to refuse cookies

Your Access to Your Personal Information

• You may request a copy of our records of personal information relating to you and may ask us to correct the information contained in those records. Note that we may not be able to correct inaccuracies in the information provided to us by others.

To submit a request to review your information, write us at the address below and include, as applicable, your name, your Member ID, your Policy Number and Government identification number, and identify the information you want to review. If you want to request a change to inaccurate information or lay a complaint, you may call us at 07034147143 or write us at the address below: 

To: Bastion Health Limited, 

2nd Floor, Union Bank Building 

1, Adeola Odeku Street, 

Victoria Island, 

Lagos 

You do not need to contact us or take any other action to preserve the privacy of your personal information as a result of this Policy. 

Effective Date and Future Changes:

• This Privacy Policy is effective as of April 2021. We may update this Privacy Policy from time to time. We encourage you to periodically review the Website and posted Privacy Policy periodically for any updates or changes. Your continued access or use of our Website shall be deemed your acceptance of all terms and conditions contained in this Privacy Policy.

Governing Laws

• The rights and obligations under this Privacy Policy are governed by the laws of the Federal Republic of Nigeria, including but not limited to the Nigerian Data Protection Regulations (NDPR) (2019).
• Data hosted outside the territory of Nigeria All Personal Information you provide to us is stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable). The data that we collect from you may be transferred to and stored at a destination outside Nigeria, the United Kingdom or the European Economic Area (“EEA”). Whenever your information is transferred to another location, we will take all necessary steps to ensure that your data is handled securely and in accordance with this Privacy Policy.
• You agree to be bound by the terms and conditions contained within this Privacy Policy, which form a legally binding agreement between us and you.
  Disclaimers and Limitations on Liability
• Bastion  makes  no  warranty  of  any  kind  whatsoever –express  or  implied –with respect  to  the  contents  of  its  Services.  Bastion  hereby  disclaims  any  and  all implied  warrantiesof  merchantability,  title, non-infringement,  and  fitness  for  a particular  purpose.  You  expressly  agree  that  your  use  of  our  Services  is  at  your sole  risk.  It  is  solely  your  independent  duty  and  responsibility  to  verify  and evaluate the accuracy, correctness, reliability and completeness of ANY Services. We make no warranty or guarantee that any content available for downloading is free from infection from any computer programming or other glitches which may contaminate damage, interfere with, destroy, intercept, or expropriate any system,  data,  or  personal  information.  We  do  not  make  any  representations, warranties,  or  guarantees –express  or  implied –regarding  quotes  or  offers provided  on  or  through  our  Services.  As  such,  Bastion  will  not  be  liable  for  any 
  Page 5of10loss or damage suffered as a result of the content, products, or services furnished from such service providers.We further make no representations, guarantees, or warranties that our Services are  appropriate  or  available  for  use  in  jurisdictions  outside  of  the  Federal Republic  of  Nigeria.  If  you  access  or  otherwise  use  our  Services  from  these jurisdictions,  you  do  so  of  your  own  volition  and  risk,  and  are  solely  responsible for compliance with local and international law.Bastion will not be held liable to anyone for any liability arising out of, or in any way   relating   to,   any   damages,   loss,  or   claim   whatsoever,   no   matter   how occasioned, in connection with or arising out of access to or use of the contents of  its  Services.  In  no  event  shall  Bastion  be  liable  for  any  special,  indirect, exemplary,  or  consequential  damages  or  any  damages  whatsoever,  including, but not limited to, loss of use, data, or profits, without regard to the form of any action,  including,  but  not  limited  to,  contract  or  negligence  orother  tortious actions, arising out of or in connection with the use, reproduction, or display of the content

Bastion’s Representations and Disclaimers

• Bastion  makes  no  representations,  warranties,  or  guarantees  with  respect  to quotes, terms,rates, coverage, or services offered to you by hospitals, insurers or other  third  parties  through  Bastion’s  Services.  Bastion  believes  the  content provided  through  its  Services  to  be  accurate,  complete,  and  current.  However, inadvertent  technical  or  factual  inaccuracies  may  arise  and,  therefore,  Bastion does not warrant that its content is accurate, complete, and current. Content that Bastion provides through its Services is meant to assist you with insurance and financial  decisions.  However,  such  information  merely  constitutes  a  general deillegalscription of insurance coverage potentially available.You  acknowledge  and  agree  that  such  recommendations  may  omit  coverage that  may  be  necessary  or  advisable  for  you  and  such  recommendations  may differ  from recommendations  that  you  might  receive  were  you  to  seek  advice specific   to   your   individual   circumstances.   You   must   submit   a   complete application  to  obtain  a  particular  coverage.  Issuance  of  insurance  coverage  is dependent  on  underwriting  approval;  availability  and  coverages  may  vary  by state.  We  also  recommend  that  you  obtain  additional  information  and  advice from your accountant, attorney, and other advisors that can take your individual circumstances into account.You hereby release Bastion of any loss,cost, damages, or claim in connection with or arising from your use of a service or product, including any fees charged.

Your Representations

• By using our Services, you represent and warrant to us that:
  You are at least 18 years of age; and
• You  are  authorized  to  purchase  and  bind  this  insurance  on  behalf  of  the individual, company or entity applying for medical coverage;
• You  authorize  Bastion,  as  well  as  its  agents  and  representatives,  to  obtain information from  a  third  party  in order  to  assess  your  insurability,  or for  any permissible purpose.

Indemnification

• By using our Services, you agree to indemnify, defend, and hold Bastion harmless against any claim, cost, fine, damages, including attorneys’ fees, arising from or related to your use of our Services.

Fees and Charges

• You may choose to purchase products or services from us while using our Services, which may result in charges and fees to you. We will inform you in advance of any such charge or fee. By submitting payment information for an accepted method of payment (“Payment Method”) through our Services, you authorize us to charge you these agreed-upon amounts, as well as any applicable taxes to your Payment Method.You  will  not  be  entitled  to  any  refund  of  charges,  fees,  or  taxes  except  as expressly provided herein, or as required under applicable law.
• You may choose to use a debit or credit card as a Payment Method to pay for  charges,  fees,  and  taxes  in  connection  with  our  Services.  Should  you choose  to  do  so,  you  warrant  that  you  are  authorized  to  use such  card  for this purpose. Should you use a debit or credit card without authorization, in whole  or  in  part,  you  will  remain  responsible  for  any  outstanding  balance, and we may alert the appropriate authorities of your misuse.
• Policy  coverage  is  renewable  annually.  Unless stated otherwise,  you  agree that your policy be automatically renewed annually. You further agree and consent to Bastion continuing to debit the same payment instrument upon renewal or similar event, if applicable.Your premium payment does not bind coverage until Bastion approves your application.  In  the  event  that  Bastion  does  not  approve  your  application; your premium payment will be refunded.
  You  may  cancel  your policy  at  any  time  by  logging  in  online  or  emailing Customer support. If you cancel your policy, we will stop your payments and will not further charge your Payment Method.

Intellectual Property Rights

• Our  names,  graphics,  and  logos  used  in connection  with  our  Services, service  marks,  icons,  page  headers,  page  layouts,  illegalscripts,  and  unique terminology are our trademarks and trade dress (collectively, “Proprietary Marks”) in the Federal Republic of Nigeria. You may not use our Proprietary Marks without  our  express  and  written  permission.  Bastion  makes  no proprietary  claim  to  any  third-party  names,  trademarks,  or  service  marks appearing on our Services as the rights related to these names, trademarks, or service marks belong to their respective owners;
• Any  information,  advice,  data,  software,  or  other  content,  which  may  be contained  in  or  downloaded  from  our  Services  (collectively  referred  to  as  “Content”), including, but not limited to, all text, graphics, charts, images, videos, icons, and renditions, are copyrighted by, or otherwise licensed to, us or our Content suppliers. We also own copyrights to a collective work in the selection, coordination, arrangement, organization, navigation, presentation, display, and selective alteration of the Content (referred to as  “Collective Work”). All software used in providing or supporting our Services (“Software”) is our property or the property of our software vendors and is protected  by  the  Federal  Republic  of  Nigeria  and  international  copyright laws.  Any  access  you  may  have,  including  but  not  limited  to,  viewing, reading,  printing,  downloading  or  otherwise  using  the  Content,  Collective Work, or Software does not waive any of our rights and does not entitle you or any third party to any ownership or intellectual property rights.
• You are solely liable for any damages arising from your infringement of our or any third-party intellectual property rights with respect to the Proprietary Marks, Content, Collective Work, Software, or third-party names, trademarks or service marks. You are solely responsible for any harm incurred to us or our  affiliates  as  a  direct  or  indirect  result  of  your  copying,  distributing, redistributing, publishing, or using the same for purposes that are expressly or impliedly in violation of this Terms of Use.

No Third-Party Binding Effect

• The  Terms  of  Use  are  between  you  and  Bastion,  and  no  provision  within  the Terms of Use confers any implied or express right to any third party. The Terms of Use do not provide you with any authority to bind Bastion in any way.

Assignment

• You  may  not  transfer,  assign,  or  license  your  rights  under  the  Terms  of  Use without our prior express and written consent.

Our Services Are Not Intended for Minors

• Our  Services  are  not directed  at  minors,  that  is,  persons  younger  than  18  years old.  If  you  are  not  at  least  18  years  old,  please  do  not  attempt  to  access  our services.  We  do  not  knowingly  contact  or  collect  personal  information  from persons  under  18  years  old,  and  such  a  person  should  not  provide  us  with  any information.

Dispute Resolution

• The Parties shall in good faith, use their reasonable best efforts to resolve any dispute that may arise in relation to this Agreement through dialogues and negotiations within twenty (20) days of such dispute’s occurrence.
• Where  the  Parties  cannot  jointly  resolve  the  dispute  wholly  or  partly,  the dispute shall be referred to and finally resolved by arbitration in accordance with the Arbitration and Conciliation Act, Cap A18 Laws of the Federation of Nigeria, 2004. The  arbitral  tribunal  shall  be  composed  of  one  (1)  arbitrator  who  shall  be jointly appointed by the Parties. Where the Parties are unable to agree on a choice of arbitrator, the nomination shall be made by the Chairman for the time being of the Nigerian branch of the Chartered Institute of Arbitrators, United Kingdom.The seat or legal place of arbitration shall be Lagos, while the language to be used in the arbitral proceedings shall be English.
• All reasonable costs and expenses attributable to the arbitration (including the  fees  of  the  arbitrator)  shall  be  allocated  equally  between  the  Parties unless   the   arbitrator   shall   determine   it   is   appropriate   under   the circumstances to allocate such costs and expenses in a different manner.

Written Modification

• The Terms of Use shall only be modified in writing. The individual employees of Bastion, Bastion’s affiliate companies, and third parties are not authorized to modify the Terms of Use except by the mechanism stated herein. Any employee offering to modify the Terms of Use is not acting as an agent of Bastion or with proper authority to bind Bastion. You agree not to rely on any statement, written or  oral,  by  any  employee  or  agent  of  Bastion  or any  third  party  with  respect  to modification or interpretation of the Terms of Use.

Notices

• Notices to you: In using our Services, you may choose to communicate with us  by  providing  us  with  feedback,  comments,  questions,  or  proposals.  In doing  so,  you  agree  to  allow  Bastion  to  use  this  information  in  any  way consistent with the Terms of Use and our Privacy Policy. When you submit contact information to us as part of an attempted or completed request for a quote or offer for goods or services, you consent to receive telephone calls, emails,   text   messages,   mailers,   or   other   similar   communications   in connection with these goods and servicesIn the event Bastion may choose or become obligated to provide you with notices  under  or  related  to  the  Terms  of  Use,  you  consent  to  receive  such notices or related communications by Bastion posting them on its Website, by  sending  them  to  you  via  an  email  address you  provided,  or  by sending them to a postal address you provided, at our discretion. You further agree that  any  such  communication  as  described  herein  satisfies  any  legal requirement that the communication must be provided in writing.
• Notices to Bastion: If you have any questions about the Terms of Use or wish to notify us in relation to your use of our Services, you may contact Bastion by email [email protected], or by calling 07034147143.24. Severability Except as otherwise provided herein, in the event that any provision contained within the Terms of Use is deemed to be unenforceable, invalid, or ambiguous, such provision shall be limited or discarded to the minimum extent necessary so that  the  remaining  provisions  of  the  Terms  of  Use  remain  in  full  force  and enforceable.25.Non-WaiverNeither party shall be deemed to have waived, in whole or in part, any of its rights granted herein by its failure to exercise, in whole or in part, any right herein.

Notification of Changes

• At its discretion, Bastion may amend the Terms of Use from time to time. We will post  any  such  material  changes  to  our  Website  along  with  a  notice  indicating that the Terms of Use have changed at least thirty (30) days prior to the effective date of these changes, when practicable. Should we materially change the Terms of Use, you may cancel your account with us by contacting us in accordance with Clause .

(“Notices  to  Bastion”)provision  of  the  Terms  of  Use  before  the effective date of the modified Terms of Use. You will not be bound by the updated Terms of Use if you cancel your account within this period.

Force Majeure

Neither party shall be responsible for any delay or failure in any performance due to acts of God, war, warlike conditions, blockade, embargoes, riots, government restriction,  labor  disturbances,  unavailability  of  anticipated  or  usual  means  of supplies,  wrecks,  epidemics,  quarantine,  fire,  flood,  earthquake,  explosion,  any unforeseen change in circumstances, or any other causes beyond any party’s reasonable control.

Entire Agreement

• You agree to be bound by the terms and conditions contained within the Terms of Use,  as  well  as  our  Privacy  Policy.  Collectively,  these  form  a  legally  binding agreement between us and you.The Terms of Use and only the Privacy Policy expressly incorporated by reference herein constitute the entire agreement of the parties and supersede any prior or contemporaneous agreements, understandings, warranties, or understandings, whether  written  or  oral,  whether  express  or  implied,  with  connection  to  our Services.

Governing Law and Jurisdiction

• You  agree  that  the  Terms  of  Use  are  governed  and  interpreted  in  accordance with the laws of the Federal Republic of Nigeria. By using our Services, you agree and submit to the exclusive jurisdiction of the High Courts of Lagos in order to resolve  any  dispute  arising  from  your  use  of  the  Services,including  but  not limited to the enforcement of any arbitration award. You further agree to waive any objection to such jurisdiction or venue.