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Draft — pending review by counsel

Privacy Notice

Adeva Health · Last updated 6 September 2026 · Questions: [email protected]

This notice explains what Adeva Health collects when you use Adeva or our website, why, who sees it, and what you can ask of us. It is written to meet the Nigeria Data Protection Act, 2023 (NDPA) and the regulations of the Nigeria Data Protection Commission (NDPC).

  1. Who this notice covers
  2. Controller or processor
  3. What we collect
  4. Why, and on what basis
  5. If you are a patient
  6. Who we share it with
  7. How long we keep it
  8. Your rights
  9. Cookies
  10. Security
  11. Contact and complaints

1. Who this notice covers

  • Laboratory owners and administrators who create and run a lab on Adeva.
  • Laboratory staff given an account by their lab.
  • Visitors to adevahealth.com, including people who book a demo.
  • Patients whose details a laboratory enters. For patients the laboratory, not Adeva, is the organisation responsible — see sections 2 and 5.

2. Controller or processor

For account holders, staff and visitors, Adeva Health is the data controller: we decide what to collect and why.

For patient data, the laboratory is the data controller and Adeva is its data processor. We store and display patient records only as the laboratory instructs, under the Data Processing Agreement. We never use patient data for our own purposes.

3. What we collect

From laboratory owners, administrators and staff

  • Name, work email address, phone number, role, permissions and the branches you are assigned to.
  • Your password, stored only as a salted bcrypt hash; we cannot read it.
  • Professional registration number, if your lab records it for report authorisation.
  • The laboratory’s name, address, licence number, logo and report settings.
  • Sign-in and activity records: time, a hash of your IP address for rate-limiting, and an audit trail of the actions you take in the product (who did what, to which record, when).

From visitors

  • What you type into the demo or contact forms: name, organisation, email, phone, message.
  • Standard server logs: IP address, browser type, pages requested, timestamps.

Patient data, on behalf of laboratories

  • Identity and contact details, demographics, and the consent the laboratory records.
  • Requests, specimens, results, reports, comments, critical-value notifications and their acknowledgements.
  • Payments, receipts and refunds for laboratory services.
  • Uploaded documents and images attached to results.

4. Why, and on what basis

PurposeDataLawful basis
Providing the service to your laboratoryAccount, staff and configuration dataPerformance of the contract with the laboratory
Keeping accounts secure and preventing abuseSign-in records, hashed IP, rate-limit countersLegitimate interest in security; legal duty to protect data
Audit trail of actions in the productWho did what, whenLegitimate interest of the laboratory and its regulators; legal duty
Transactional email (verification, resets, invitations, result delivery)Email address, message contentPerformance of the contract
Responding to enquiries and demo requestsForm contentsYour request; legitimate interest
Error monitoringStack traces and request metadataLegitimate interest in a working service
Processing patient data for the laboratoryPatient recordsLaboratory’s instructions under the DPA; the laboratory’s own lawful basis

We do not sell personal data, and we do not use it for advertising or profiling.

5. If you are a patient

Your laboratory entered your details so it could test your specimen and report the result. The laboratory decides what is recorded, who may see it, and how long it is kept, under its own professional and legal duties. To see, correct or delete your record, or to withdraw consent, contact the laboratory that tested you. If you write to us instead, we will pass your request to the laboratory and help it respond.

Adeva staff cannot see your record in the ordinary course of operating the service. Access for support is granted only by your laboratory’s administrator, is time-limited, and is recorded in the laboratory’s audit trail.

6. Who we share it with

We share data only with the providers that run the service for us, each bound by contract to process it on our instructions:

ProviderPurposeRegion
RailwayApplication hosting and the PostgreSQL database that holds all account and laboratory dataUnited States and European Union regions, as configured per environment
CloudflareObject storage for uploaded files (laboratory logos, result documents and images), DNS and edge deliveryGlobal network; storage in the configured region
ResendTransactional email: verification, password reset, invitations and result-delivery messagesUnited States
SentryError monitoring for the application; receives stack traces and request metadata, not laboratory recordsUnited States

Where a provider stores data outside Nigeria, the transfer is made under safeguards the NDPA permits, including contractual clauses with the provider. We will disclose data to a regulator or court only where the law requires, and we will tell the laboratory unless we are prohibited from doing so.

7. How long we keep it

  • Account and laboratory data: for as long as the laboratory holds an account, then ninety days for export, then deleted.
  • Patient data: for as long as the laboratory instructs; deleted with the laboratory’s account or on its instruction, subject to the laboratory’s own retention duties.
  • Audit trail: for the life of the laboratory’s account; it is part of the laboratory’s record.
  • Sign-in attempt counters and hashed IPs: rolling windows of hours, then discarded.
  • Enquiry and demo forms: up to twelve months after the last contact.
  • Backups: deleted data leaves backups within the backup retention cycle of our hosting provider.

8. Your rights

Under the NDPA you may ask us to:

  • confirm whether we hold personal data about you, and give you a copy;
  • correct data that is inaccurate or incomplete;
  • delete data we no longer have a reason to keep;
  • restrict or object to processing based on legitimate interest;
  • give you your data in a portable form;
  • withdraw consent where consent is the basis.

Write to [email protected]. We answer within thirty days. Where the laboratory is the controller, we forward the request to it and support its answer.

9. Cookies

Adeva sets one session cookie when you sign in. It is strictly necessary: it holds your signed session and nothing else, is not readable by scripts, and is deleted when you sign out or the session expires. We set no advertising or analytics cookies and use no third-party trackers on the product or the website. Because only strictly necessary cookies are used, no cookie banner is shown.

10. Security

Every laboratory’s data is isolated by row-level security in the database, passwords are hashed, transport is encrypted, access is by role, permission and branch assignment, and every action is audited. The detail is on the Security page. If we learn of a breach affecting your data we will notify the affected laboratory without undue delay and the NDPC within the period the law sets.

11. Contact and complaints

Privacy questions and requests: [email protected]. If you are not satisfied with our answer you may complain to the Nigeria Data Protection Commission.

Counsel to confirm: the registered entity and address, whether a Data Protection Officer must be named, the international-transfer mechanism for each provider, and the retention periods against the laboratories’ regulatory duties.

Terms of ServiceData Processing AgreementSecurity

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