1. Who is responsible
MONOVELLA LTD, RC 9872896, 33 Ilupeju Street, Alabata Road, Camp, Abeokuta, Ogun State, Nigeria ("Monovella") decides why and how your personal data is used, so we are the data controller. Our data protection officer is Abdulazeez Jimoh, [email protected], +2348141284556. Contact them for anything in this notice. We are registered with the Nigeria Data Protection Commission (NDPC) as a controller of major importance, and our DPO's contact details are provided to the NDPC.
2. What we collect
| Data | When | Why |
|---|---|---|
| Phone, email, password (stored hashed), one-time codes | Sign-up and sign-in | Account and security |
| The concern you describe, the visit format and area you choose, the result of our check on it, and, if we ask them, your answers to five quick yes/no questions | Before booking | Checking for signs of an emergency, matching your concern to a specialty, and showing it to the specialist you book so you don't have to repeat it |
| Health information: case notes, images and documents your specialist attaches to them, Care Plans, prescriptions, lab requests, and lab results | Care Journey | Providing the care you booked |
| Payment records (amounts, splits, refunds; we do not see your card) | Paying | Booking, refunds, accounts |
| Video call (streamed; we do not record calls) | Video consultation | Delivering the consultation |
| Messages we send you (codes, reminders, results ready) and delivery status | Ongoing | Running the service |
| Device and log data | Ongoing | Security, fraud and abuse prevention, proving what happened |
| Opted-in public-site analytics: approved page path/title and fixed marketing-link name | Only after you allow analytics | Understanding aggregate public-site use |
Health information is sensitive personal data. We handle it under stricter rules and only with your separate consent.
3. Why we use it, and on what basis
| Purpose | Basis |
|---|---|
| Create and secure your account; verify your phone or email | Contract; our legitimate interest in preventing fraud |
| Book, take payment, refund, remind you | Contract |
| Concern triage: checking your concern for an emergency and matching it to a specialty, including the AI step below | Your consent (health information) |
| Provide the consultation, Care Plan, prescription document and lab steps, share results with your specialist | Your consent (health information); vital interests where a critical result needs urgent action |
| Keep legally required records, tax and accounting | Legal obligation |
| Security, audit logs, resolving Alerts and disputes | Legitimate interest |
| Marketing messages | Only with your separate consent; you can say no and still use Monovella |
| Optional public-site analytics | Your cookie consent |
Concern triage. Before you book, you describe your concern in your own words and choose a visit format (video, in person, or either) and, for an in-person visit, an area. We check the words for signs of an emergency and match the concern to a specialty. You then choose a specialist yourself; the specialist you book sees your concern in your words, so you don't have to repeat it. Triage does not diagnose you, give clinical advice, recommend treatment or talk to you. It works in this order:
- Our own emergency rules run first, on our own server. They look for emergency warning signs in English and Nigerian Pidgin. A match is treated as an emergency, whatever else happens.
- An AI model, when it is switched on. If our rules find nothing, a small AI model from OpenAI reads a copy of your concern in which your name, email, phone numbers and any other long numbers are replaced with placeholders, together with the rules it must follow. It sees nothing else: not your account, contact details, any identifier, booking or record. It says which emergency signs it finds, picks one specialty, and says whether you gave enough detail. It can add an emergency but never remove one our rules found. We keep its verdict (which signs it flagged, the specialty and why), never what it wrote. We switch this step on only once OpenAI has signed data processing terms with us and confirmed in writing that it keeps no copy of the request.
- Five quick yes/no questions, if the model is switched off, slow, fails, or is unsure whether it is an emergency. Any "yes" is treated as an emergency.
If no specialty was chosen, your concern goes to General Practice.
If the check finds an emergency, you can't book in that session. We show you to call 112 or go to the nearest hospital emergency department, and a person at Monovella is alerted and may contact you. You can come back and book later, and you are always free to get care elsewhere. The stop is made by the check, not by a person; if you think it was wrong, you can raise it with the DPO under your rights in section 7. Nothing about triage is sent to you by SMS or email.
4. Who sees your data
Inside Monovella: only staff who need it. The admin team sees verification, Alerts and recovery queues, not clinical content beyond what is needed to resolve an Alert.
Among providers, each sees only their part:
- Your specialist sees your consultation and results for that Care Journey. Their case note, and any images or documents they attach to it, stay with them; you see an attachment when they share it with you in your Care Plan. Your copy of your data includes your Care Plans and anything shared in them, not the specialist's case note or attachments they haven't shared.
- A laboratory sees only the booking sent to it.
- Your prescription is available only through the permitted Care Journey record.
Providers are independent professionals who also hold duties of confidentiality and their own data protection duties.
Outside services that touch your data (our processors):
| Service | What it sees | Why |
|---|---|---|
| TrueHost Cloud (servers in Nigeria) | All the data above, stored on our behalf | Running Monovella |
| OpenAI | Only when the AI step of concern triage is switched on: a copy of the concern you type, with your name, email, phone numbers and other long numbers replaced; never your account, contact details, identifiers, bookings or records | Concern triage (section 3) |
| LiveKit | Video and audio of your call | Video consultations |
| Paystack | Payment details and amounts | Payments and refunds |
| Termii | Your phone number and the message. Messages carry no diagnosis, result or prescription. | SMS and messaging |
| ZeptoMail | Your email and the message | |
| Google Analytics | Only opted-in activity on approved public marketing/legal pages; never health, booking, account or form data | Aggregate website analytics |
We update this list whenever we add or change a service.
We don't sell your data.
5. Sending data outside Nigeria
Our database, private file store and backups are kept in Nigeria. Some of the services above process data outside Nigeria. We transfer it only under the data processing terms and safeguards recorded for each provider. Where consent is the appropriate transfer basis, we ask separately: cookie consent for optional Google Analytics, and the transfer consent you give before a video consultation.
When the AI step of concern triage is switched on, the redacted copy of your concern goes to OpenAI, which processes it in the United States. That copy is health information. We send it under OpenAI's data processing terms, with storage of the request switched off, and on the basis of your consent to our processing your health information as this notice describes. Details of the safeguards are in our processor agreements; ask the DPO for a summary.
6. How long we keep it
We keep data only as long as we need it for its purpose or the law requires, then delete or irreversibly de-identify it. Our Data Policy sets out the full retention schedule; in short: health records (case notes and their attachments, Care Plans, prescriptions, results, and the concern you describe with the result of our check on it) for 6 years after your Care Journey closes, or 12 months after you describe a concern that never leads to a booking; answers to the five quick triage questions for 12 months; payment records for 6 years; account details for 12 months after you close your account; one-time-code logs for 90 days. Keeping a record can limit what we can delete when you ask; we will tell you which parts and why.
7. Your rights
You can ask us to: tell you what we hold and give you a copy; correct it; delete it; restrict or object to its use; give you your data in a portable form; and not be subject to a decision made only by automated means (section 3 explains how a person is involved when concern triage stops a booking). You can withdraw consent at any time (withdrawing doesn't affect what was lawfully done before). Email the DPO. We reply within 30 days. You may complain to the Nigeria Data Protection Commission (ndpc.gov.ng).
8. Security and breaches
We use access controls limited by role, encryption in transit and at rest, multi-factor authentication for admins and audit logs. If a breach is likely to put your rights at risk we tell the NDPC within 72 hours of becoming aware, and we tell affected people immediately.
9. Cookies and similar tools
See our Cookie Policy for the cookies and browser storage we use, including optional Google Analytics. Analytics is limited to approved public marketing/legal pages and never runs in the care or account experience.
10. Changes
We will tell you about material changes and, where the law needs it, ask for consent again.
Notice for providers (specialists, laboratories)
We also process your name, contact details, licence and credential documents, payout account details, profile content, booking and payment history, and admin decisions about you. Purposes: verifying you before you can be booked or paid (including that your account name matches the name on your licence), paying you, refund recovery, audit and safety. Basis: contract and legal obligation, and legitimate interest in platform safety. Your public profile shows only what you submitted and approved; credential and payout details never appear. Your role in your patients' data is in the Terms of Service, Part B.