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.

PERSONAL INFORMATION WE COLLECT

(i) We receive information from you to build relationships and serve your health and related needs. We also receive information about you directly from you, or from other health practitioners whom you have seen and authorized to disclose to us. This information may include, amongst other things:

· Personal details: e.g., name, gender, Date of Birth; marital status, body statistics of you and your dependents etc.

· Contact Information (e.g., phone number, address, and email address);

· Financial information (e.g., bank account, debit and credit card account numbers, balances and information related to payment for health care services), and (as applicable) your 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.

· Sensitive personal information/information necessary to conduct our business (e.g. health history, family health history (including mental);

(ii) 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.

(iii) 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;

(iv) 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 laws.

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, third party 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. 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 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,

8th Floor, South Atlantic Petroleum Towers

Plot (98(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 May 2024. 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) and the Nigerian Data Protection Act (NDPA) (2023).

· 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 warranties of 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 loss 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 or other 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, illegal scripts, 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.

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 services. In 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 at [email protected], or by calling 07034147143.

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

Non-Waiver

Neither 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 the provisions of “Notices to Bastion” under 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, labour 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.

Dispute Resolution 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.

· 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 Mediation Act (2023). 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.