2.1“Personal Information” in this Privacy Policy, means information about you that is personally identifiable to you, such as your contact information (e.g. name, address, email address, or telephone number), personally identifiable health or medical information (“Health Information”), personal identification documents (such as driver’s license, voter’s card etc.) and any other non-public information that is associated with such information. We will always seek your explicit consent before collecting or processing any sensitive medical or health-related information.
“De-Identified Information”, means information that is neither used nor intended to be used to personally identify an individual.
2.2 Information We Receive or Collect from You
a) Registration Data: When you register or create an account, you provide us with certain information, which includes your email address, telephone number, date of birth, gender, and zip or postal code (the “Registration Data”), as well as a password for your account.
b) Payment Information: If you choose to use a fee-based Service such as advertisement or make a donation, you will be requested to provide (at a minimum) your name and payment information including payment card information (“Payment Information“). A third-party service provider that handles payments for us will also receive your payment card information.
c) Information You Choose to Provide to Us: You have the ability to provide a variety of information during your interactions with us and the Kaci Automated assistant & App, such as emails you may send us, information you respond to, and emails or newsletters that you sign up to receive. Kaci Automated assistant & App or third parties acting on our behalf receive data from you whenever you provide us with information.
d) Contact Information: If you choose to participate in research studies, or sign up for certain features, you may provide us, and we may collect, your contact information, including your name, mailing address, and phone number (“Contact Information”).
e) De-identified Data. We use de-identified data for research and development of new products or tools, to refine our algorithms and machine learning applications, and to improve the App and the services we provide. We may disclose such information publicly and to third parties, for example, in public reports about health, to partners under agreement with us, or in benchmarking information we provide to the medical community.
2.3 Information We Receive from Third Parties
a) Social Media Accounts: We may obtain Personal Information about you through the Mobile Application, or other third party social media services, such as Facebook and Twitter, if you choose to link our Services with third party social media accounts (“Social Media Account”) by either: (i) providing your Social Media Account login information to us through the Services; or (ii) allowing us to access your Social Media Account, as is permitted under the applicable terms and conditions that govern your use of the respective Social Media Account.
2.4 Information we collect via technology
a) Activity on the app, the automated assistant and our websites: We may keep track of some of the actions you take on the app, the automated assistant and our websites, such as the content of searches you perform via the Mobile Application or on the app, the automated assistant and our website.
b) Access Device and Browser Information: When you access the app, the automated assistant and our website from a computer or other device, we may collect anonymous information from that device, such as your Internet protocol address, browser type, connection speed and access times (collectively, “Anonymous Information”).
c) Cookies: We may use both session Cookies (which expire once you close your web browser) and persistent Cookies to make the app, the automated assistant and our website and Services easier to use, to make our advertising better, and to protect both you and Kaci Automated assistant & App. You can instruct your browser, by changing its options, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. If you do not accept Cookies, however, you will not be able to stay logged in to the app, the automated assistant and our websites. We may also use Pixels to make the app, the automated assistant and our websites and Services easier to use and to make our advertising better by, for example, summarizing usage patterns. We presently do not honour “Do Not Track” requests across all parts of our Sites. However, you can manage cookies by adjusting your browser settings to refuse or delete cookies, or by using cookie preference tools (such as banners or pop-up settings) provided on our Website.
d) Real Time Location: Certain features of the app, the automated assistant and our website use GPS technology to collect real-time information about the location of your device so that the app, the automated assistant and our website can connect you to a Security Agency, Healthcare ProfessionalServices or Ambulance service which are licensed or authorized to provide Services in the area or jurisdiction where you are located. When accessing Google Maps services on our Sites, you are agreeing to Google’s Terms of Service and Privacy Policy.
e) Mobile Services: We may collect non-personal information from your mobile device or computer. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the Kaci app, other application(s) and information about the type of device or computer you use. In addition, in the event our application(s) crashes on your mobile device we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s).

3.1 Generally, Kaci Help App and Automated Assistant use the information we collect for the following purposes:

• To operate, provide, maintain, improve, and enhance our Services;

• To understand and analyze how you use our Services and to develop new products, services, features, and functionality;

• To personalize your experience on our Services, such as by providing tailored content. For example, we use your phone number and email address to help you create, log into, and manage your account on our Services. This lets us personalize your experience and give you relevant information. It also powers the features that help you better understand, engage with, and track your safety, health, or emergency-related activities, and to present you with personalized, relevant information;

• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you. We also may use the information that we learn about you to assist us in advertising our Services on third-party websites. Where required under applicable law, we will only send you marketing communications with your consent;

• To communicate with you via email, text messages, WhatsApp, push notifications, and phone calls, in order to provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;

• To facilitate transactions and payments;

• For our business purposes, such as audits, quality assurance, fraud prevention, and responding to trust and safety issues that may arise;

• For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency;

• For other purposes for which we provide specific notice at the time the information is collected; and

• To aggregate or otherwise de-identify information collected through the Services and use and disclose it for other business purposes after the data can no longer be reasonably linked to an identifiable person.

3.2 De-Identified Information
We may use de-identified information without any restrictions.

3.3 Information You Share with Third Parties
This Privacy Policy applies only to information we collect through Kaci Help App, the Automated Assistant, and in email, text, WhatsApp, and other electronic communications sent through or in connection with our Services. This Policy DOES NOT apply to information collected by any third party. When you click on links on the App, the Automated Assistant, or our website, you may leave our Services. We are not responsible for the privacy practices of other sites, and we encourage you to read their privacy statements.

3.4. Kaci Help Smart Tags (NFC)

3.4.1 Overview

Kaci Help Smart Tags are reusable NFC-enabled products (including cards, wristbands, key holders, stickers, rings, and other compatible devices) that allow users to securely share selected information from their Kaci Help account by tapping the Smart Tag with an NFC-enabled device or by searching using the user’s Kaci Security Number (KSN), where applicable.

The Smart Tag itself does not permanently store your personal information. Instead, it securely references your Kaci Help Profile (“KHP”) using your Kaci Security Number (KSN). The KSN is a randomly generated unique identifier that can be changed or regenerated by Kaci Help in accordance with the operation of the Service.

3.4.2 Information We Collect and Process

To provide Kaci Help Smart Tag services, we may collect, process, and store information including, but not limited to:

• Your name, photograph, phone number, email address, and selected location;
• Blood group and other profile information you choose to provide;
• Trusted contact information, including names, phone numbers, email addresses, and relationship types;
• Health and medical information that you voluntarily provide, including medications, allergies, medical conditions, date of birth, and other emergency information;
• Identification documents that you voluntarily upload, such as National Identity Card, Driver’s Licence, International Passport, Voter’s Card, Student ID, Workplace ID, HMO Card, or other supported identification documents;
• Information relating to your Smart Tag, including KSN, activation status, programming history, and Smart Tag management;
• Search, access, download, and activity logs relating to your KHP and KHC.

3.4.3 Kaci Help Profile (KHP)

KHP is your shareable profile.

Where you choose to activate a Kaci Help Smart Tag or otherwise enable KHP, selected information from your account may be displayed to persons who tap your Smart Tag or access your KHP through the Kaci Verify Hub at verify.kacihelp.com using a valid Kaci Security Number (KSN), subject to the functionality of the Services.

Depending on your settings and the Services, KHP may display information such as:

• Name;
• Photograph;
• Phone number;
• Email address;
• Selected location;
• Blood group;
• Guardians (Trusted/Emergency) contacts;
• Verification badges; and
• Other profile information that you have chosen to make available.

KHP is intended to help identify you, facilitate communication during emergencies, and support other legitimate purposes provided through the Services.

Only the information designated by Kaci Help for public or emergency sharing will be displayed through KHP.

3.4.4 Kaci Help Card (KHC)

KHC is your protected profile containing more detailed and sensitive information.

KHC may include:

• Date of birth;
• Medical information;
• Medications;
• Allergies;
• Uploaded identification documents;
• Emergency and health-related information; and
• Other sensitive information you choose to provide.

KHC is not publicly accessible through your Kaci Help Smart Tag, ordinary KSN searches, or the public Kaci Help Profile (KHP).

Access to KHC is restricted to:

• You, after successful authentication into your Kaci Help account; and
• Authorized agencies or organizations that have been approved by Kaci Help and authenticated through the Kaci Verify Hub at verify.kacihelp.com, where such access is required for lawful, emergency, healthcare, security, identity verification, or other legitimate purposes permitted by applicable law.

Kaci Help implements authentication, authorization, monitoring, and audit controls to protect KHC and reserves the right to restrict, suspend, or revoke access where misuse, unauthorized access, fraud, security threats, or violations of applicable law, these Terms, or this Privacy Policy are detected or reasonably suspected.

3.4.5 Guardians (Trusted/Emergency) Contacts

If you choose to add trusted contacts or guardians to your account and enable their display within your Kaci Help Profile (KHP), their names, phone numbers, email addresses, relationship to you, and other selected contact information may be displayed to persons who access your KHP through your Kaci Help NFC Smart Tag, a valid Kaci Security Number (KSN), or other authorized methods provided by Kaci Help.

By adding trusted contacts or guardians, you represent and warrant that you have informed them that their information may be processed and displayed through your KHP where such feature is enabled, and that you have obtained their consent or other lawful authority required under applicable law before providing their personal information to Kaci Help.

Kaci Help processes such information based on your instructions, your representations regarding consent or lawful authority, this Privacy Policy, and applicable data protection laws. You are responsible for ensuring that the information you provide is accurate and that you have the necessary permission to add or update any trusted contact or guardian.

3.4.6 Legal Basis for Processing

Kaci Help processes information relating to Smart Tags on one or more lawful grounds, including:

• Your consent;
• Performance of our contract with you;
• Compliance with applicable legal obligations;
• Protection of your vital interests or those of another person during emergencies;
• Our legitimate interests in operating, securing, improving, and administering the Services, provided such interests do not override your fundamental rights and freedoms.

Sensitive personal information, including health information and uploaded identification documents, will be processed only where permitted under applicable law and, where required, with your explicit consent.

3.4.7 User Control

You remain in control of your Smart Tag information.

Subject to applicable law and technical limitations, you may:

• Update your profile information;
• Add, edit, replace, or delete uploaded identification documents;
• Add, edit, or remove trusted contacts;
• Activate or deactivate your Smart Tag;
• Reprogram your Smart Tag with a new KSN where applicable;
• Delete your account or request deletion of your personal data in accordance with this Privacy Policy.

Changes made to your account may require your Smart Tag to be reprogrammed before the updated information becomes accessible.

3.4.8 Security and Monitoring

Kaci Help maintains audit logs and monitoring systems to protect the integrity of the Smart Tag and verification services.

Users may search for another user’s Kaci Help Profile (KHP) only by entering a valid Kaci Security Number (KSN). Before a search is completed, the user may be required to select or provide a reason for the search.

Authorized agencies and organizations that have been approved by Kaci Help may search for users through the verification platform and, where authorized, access the Kaci Help Card (KHC) for lawful, emergency, healthcare, security, identity verification, or other legitimate purposes permitted by applicable law.

All searches, profile access, downloads, and related activities may be logged, including the account used, date and time, search reason, IP address, device information, and other relevant audit information where applicable. These records may be used for security, fraud prevention, compliance, investigations, service improvement, and enforcement of our Terms.

Kaci Help reserves the right to monitor usage, investigate suspicious or abusive activity, suspend or terminate search privileges, deactivate Smart Tags, restrict access to KHP or KHC, or block any user, agency, or organization that violates our Terms, this Privacy Policy, or applicable law.

3.4.9 User Responsibility

You are solely responsible for the information you choose to include in your KHP.

By activating or using a Kaci Help Smart Tag, you acknowledge and understand that individuals who access your KHP through your Smart Tag or a valid KSN may view, save, download, print, copy, or capture the information you have chosen to make available. You should only make information available that you are comfortable sharing for identification, emergency response, or related purposes.

3.4.10 Your Rights

Subject to the Nigeria Data Protection Act, 2023 (NDPA), and other applicable laws, you have the right to request access to your personal data, correct inaccurate information, withdraw consent where processing is based on consent, restrict or object to certain processing activities, request deletion where applicable, and exercise any other rights available under applicable data protection laws. Nothing in this section limits any rights available to you under the NDPA or other applicable laws.

Kaci Chatbot & App may share or otherwise disclose Personal Information in the circumstances described below.

4.1 Affiliates: We may disclose Personal Information to our affiliates or partners to provide the Services or for other purposes for which the information was collected.

4.2 Vendors and Service Providers: We may share Personal Information we receive with vendors, relevant authority (emergency services or law enforcement upon your request) and service providers in connection with the provision of the Services and features of Kaci. In the event Personal Information is (a) to be used for a purpose that is materially different from the purposes for which the Personal Information was originally collected or subsequently authorized, or (b) transferred to a third party acting as a data controller, Members will be given, where practical and appropriate, an opportunity to opt out of having non-sensitive Personal Information used or transferred. For sensitive information, including health related information, members will opt in before such use or transfer.

In some instances, Kaci Chatbot & App may retain other service providers to perform functions on our behalf, including, but not limited to, website developers and IT services providers.

4.3 Analytics Partners: We may make certain Personal Information available to third parties for analytics purposes, including: (a) for Kaci Chatbot & App business or marketing purposes, or (b) to leverage third-party tools to understand Members’ interests, habits, and usage patterns, and/or functionality available through our Services. We only share your Personal Information with analytics partners to improve our own Services and/or to deliver healthcare to you. We do not sell your Personal Information to advertisers.

4.4 As Required by Law and Similar Disclosures: We may access, preserve, and disclose Personal Information if we believe doing so is required or appropriate, in our sole discretion, to: (a) comply with any applicable law, regulation, legal process or governmental requests, such as a court order or summons, or otherwise cooperate with law enforcement or governmental agencies; (b) take precautions against liability; (c) protect your, our, or others’ rights, property, or safety; (d) investigate and defend ourselves against any third-party claims or allegations; and (e) protect the security or integrity of our Services and any facilities or equipment used to make our Services available. For the avoidance of doubt, the disclosure of Personal Information may occur if you post any objectionable content on or through the Services.

4.5 Social Media Services: Our Services may allow you to, upon your direction, share Personal Information with certain social media services, such as Facebook, Twitter, Pinterest, and Google Plus. Please consider any impact on your privacy and anonymity when posting content to any and all social media services. You understand and agree that the use of Personal Information by any social media services will be governed by the respective privacy policies of those social media services and your settings on their platforms. We encourage you to review their privacy policies.

4.6 Marketing: We do not rent, sell, or share Personal Information about you with nonaffiliated companies for their direct marketing purposes, unless we have your permission.

4.7 Mergers, Sales, or Other Asset Transfers: We may disclose and otherwise transfer Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Kaci Automated assistant & App prohibits registration by and does not knowingly collect personal information from anyone under the age of 13 years. However, sensitive personal information relating to a child less than 18 years may only be collected using an account set up and managed by an adult parent or guardian. In the event we come to the knowledge that we have collected information from a child under the age of 10 years we will take all measures necessary to remove such information from our servers. If you believe that we might have any personal information from a child under 10, please contact our team at [email protected].

We retain your Personal Information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or as required by applicable law (for example, financial records may be retained for up to 5 years). Once the retention period expires, your data will be securely deleted or anonymised. When determining the retention period, we take into account various criteria, such as the type of Services provided to you, the nature and length of our relationship with you, the impact on the Services we provide to you if we delete some Personal Information from or about you, and mandatory retention periods provided by law and the relevant statute of limitations.

8.2 Required Account Information: Certain Personal Information is required for account functionality and can be edited but not deleted. For example, you can edit, but not remove, the phone number required for login.

8.3 Health Records: You can amend your health information and can add information to make your information more accurate or complete. Accordingly, if you would like to request access to, or to limit the use or disclosure of Personal Information, please contact us.

8.4 Public Content: You can request the removal of Public Content by contacting us.

8.5 Marketing Communications: You can unsubscribe from our marketing communications, such as announcements of new features or special offers, via the link provided in the promotional messages. We will never share your phone number, email, or other contact information with third parties for their own marketing purposes without your explicit permission. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

8.6 Notifications: We will ask you if you want to receive notifications when you open an account with us. If you agree, we may send you SMS, WhatsApp, email, or mobile push notices, providing you with account-related reminders or updates, or letting you know that you have a message on our Services. You may opt out at any time by adjusting your notification settings in the Settings page.

8.7 Do Not Track: There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

8.8 Delete Your Account: You may delete your account at any time. To do this, sign in with your phone number, go to the Profile/Settings page, and choose the Delete Account option. Logging out is different from deactivation and will not remove your account data.

9.1 We will continue to evaluate this policy against new technologies, business practices, changes in law, and our member needs, and may make changes to the policy accordingly. Please check this page periodically for updates. If we make any material changes to this policy, we will post the updated terms of the policy on the Services, and provide you notice of such changes, which may include notice by email through a message sent to the email address you use to access the Services.

9.2 Any material changes to this policy will be effective within thirty (30) calendar days following our dispatch of an email notice to you. These changes will be effective immediately for new users of the Services.

9.3 Please note that at all times you are responsible for updating your information to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice.

9.4 If you do not wish to permit changes in our use of your information, you must notify us prior to the effective date of the changes that you wish to deactivate your account.

9.5 Continued use of the Services following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

We primarily comply with the Nigeria Data Protection Regulation (NDPR). Where applicable, we also comply with the General Data Protection Regulation (GDPR) and other relevant privacy laws, particularly when our Services are used by residents of jurisdictions outside Nigeria.
To ensure adherence, Kaci App conducts regular compliance audits and follow-up investigations to verify the accuracy of our privacy practices and commitments. Employees found in violation of this Policy may face disciplinary action. We also provide training to support effective implementation and compliance with our privacy practices.
If you identify an inaccuracy or wish to make a complaint about a potential violation, you may contact us using the information provided below.
10.1 Enforcement
Kaci reserves the right to enforce this Policy and take all necessary actions to protect our platform, data, and users. By using our services, you agree not to hold Kaci, its affiliates, or employees liable for any claims, losses, damages, or disputes arising from your use of our platform, except as required by applicable law. You further agree to indemnify and hold harmless Kaci, its affiliates, officers, and employees from and against any claims, liabilities, damages, losses, or expenses (including reasonable legal fees) resulting from your violation of this Policy, misuse of our services, or breach of applicable laws.
10.2 Dispute Resolution
Questions or concerns regarding our use or disclosure of information may be directed to our team at [email protected]. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of information in accordance with the principles contained in this Policy. Any dispute regarding this Policy shall be resolved following the dispute resolution mechanisms outlined in our Terms of Use.
10.3 Governing Law and Jurisdiction
This Policy, and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it, shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria. You agree that the courts of Nigeria shall have exclusive jurisdiction to settle any dispute or claim arising from or related to this Policy or your use of Kaci services.

If you have any questions or would like further clarification about the app, the chat bot and our websites or Services, please contact us at [email protected]. We love to hear from you. If you have an idea that can make Kaci better any feedback concerning our services, contact us at [email protected].