1. Who We Are
Nexlyfe is a digital health interpretation platform operated by Nexlyfe ([PLACEHOLDER: registered company name and number]), incorporated in Uganda. We connect patients using diagnostic devices with Uganda Medical and Dental Practitioners Council (UMDPC)-verified doctors for remote medical interpretation services.
Contact: [PLACEHOLDER: support@nexlyfemed.com]
Address: [PLACEHOLDER: physical address, Kampala, Uganda]
2. Data We Collect
We collect the following categories of personal data:
- Identity data — full name, phone number, date of birth
- Health data — CGM glucose readings, GI camera images, cardiac recordings, medical history, diagnosed conditions
- Payment data — MTN MoMo or Airtel Money phone number, transaction references (we do not store full payment credentials)
- Device data — device type, operating system, app version
- Usage data — screens visited, actions taken, error logs
- Communications — messages between patients and doctors within a consultation
3. How We Use Your Data
- To verify your identity via OTP and maintain your account
- To connect you with a UMDPC-verified doctor for interpretation
- To process and hold payments securely in escrow
- To deliver doctor reports to you
- To send you SMS or WhatsApp notifications about your consultation
- To detect fraud and prevent abuse of the platform
- To comply with applicable Ugandan law
4. Who We Share Your Data With
We share your data only with:
- Your chosen doctor — health data, uploaded files, and messages are shared only with the doctor you select
- Flutterwave — our payment processor, for processing mobile money transactions
- Africa's Talking — our SMS and WhatsApp notification provider
- Cloudinary — secure cloud storage for uploaded medical files and images
- Sentry — anonymised error tracking to improve app stability
- Resend — transactional email delivery for system alerts
We do not sell, rent, or trade your personal or health data to any third party for marketing or commercial purposes.
5. Health Data — Special Category
Health data is a special category of personal data under the Uganda Data Protection and Privacy Act 2019. We treat it with the highest level of care. Your health data is:
- Encrypted in transit and at rest
- Accessible only to you and your chosen doctor
- Never used for advertising or profiling
- Retained only for as long as necessary (see Section 7)
6. Legal Basis for Processing
We process your data on the following legal bases under the Uganda Data Protection and Privacy Act 2019:
- Consent — you agree to this policy when you create an account
- Contract — processing is necessary to deliver the interpretation service you paid for
- Legal obligation — we may process data to comply with Ugandan law
7. Data Retention
- Account data — retained while your account is active and for 2 years after deletion
- Health data and reports — retained for 5 years to support clinical continuity
- Payment records — retained for 7 years as required by Ugandan financial regulations
- Error logs — retained for 90 days
8. Your Rights
Under the Uganda Data Protection and Privacy Act 2019, you have the right to:
- Access the personal data we hold about you
- Correct inaccurate data
- Request deletion of your data (subject to legal retention obligations)
- Object to processing of your data
- Withdraw consent at any time
- Lodge a complaint with the Personal Data Protection Office of Uganda
To exercise any of these rights, contact us at [PLACEHOLDER: support@nexlyfemed.com]. We will respond within 21 days.
9. Cookies and Tracking
The Nexlyfe mobile app does not use cookies. Our admin and clinic web portals use a session cookie solely for authentication. We do not use advertising or tracking cookies.
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes via SMS or in-app notification. Continued use of Nexlyfe after changes constitutes acceptance of the updated policy.
11. Contact Us
For any privacy-related questions or requests:
Email: [PLACEHOLDER: support@nexlyfemed.com]
Address: [PLACEHOLDER: Kampala, Uganda]
Phone: [PLACEHOLDER: +256 XXX XXX XXX]