Privacy Policy

What This Policy Covers

This Privacy Policy explains how AirTook Health Technology Ltd ("AirTook", "we", "us") collects, uses, shares, and protects your personal data when you use the AirTook website, mobile apps, and related services — including Aira, doctor consultations, the Wallet, Family Hub, CarePoints, pharmacy and laboratory fulfilment, HMO and corporate integrations, and Wellness Org / AirTookademy content (together, the "Platform").

This Policy applies to Patients, Guardians managing a Dependent's profile, Practitioners, and staff of our Corporate, HMO, Fulfilment Partner, and Wellness Org partners, to the extent each interacts with the Platform. It should be read alongside our Terms of Service.

AirTook Health Technology Ltd

Registered in Nigeria. AirTook Health Technology Ltd ("AirTook", "we", "us") is the data controller responsible for your personal data collected through the AirTook platform. For consultations, the attending Practitioner is an independent data controller for the clinical notes they personally create, in line with their own professional obligations.

Privacy enquiries, including requests to our Data Protection Officer: privacy@airtook.com

Key Terms Used in This Policy

• "Personal data" — any information relating to an identified or identifiable individual.
• "Health data" — personal data concerning your physical or mental health, including the provision of healthcare services, which reveals information about your health status.
• "Processing" — anything done with personal data: collecting, storing, using, sharing, or deleting it.
• "Processor" — a third party that processes personal data on our instructions (for example, our cloud hosting provider or SMS provider), rather than for its own purposes.
• "NDPA" — the Nigeria Data Protection Act 2023; "NDPC" — the Nigeria Data Protection Commission, its regulator.

Who You Are

• Identity data — full name, date of birth, sex, profile photo, and, if you choose to provide it, your National Identification Number (NIN) for identity verification.
• Contact data — email address, phone number, and address.
• Account data — your sign-in method (password, App PIN, or Apple/Google sign-in), account status, and role (Patient, Practitioner, Guardian, or partner staff).
• Family Hub data — where you use Family Hub, the identity information you enter for a Dependent who has no account of their own.

Your Health Information

• Health records — blood group, genotype, allergies, medications, medical and surgical history, and any conditions you choose to track.
• Consultation history — doctor notes, diagnoses, prescriptions, lab requests, and lab results.
• Vital signs & tracked data — blood pressure, weight, temperature, blood sugar, SpO₂, sleep, mood, nutrition, menstrual cycle, and any other measurement you choose to log.
• Aira conversations — messages you exchange with Aira, including any health information you share in the course of a conversation.
• Emergency Medical ID — the subset of your health data (blood group, genotype, allergies, conditions, medications, emergency contacts) you choose to make available, in a masked form, to a first responder scanning your Medical ID.

Health data is treated by AirTook as a special, sensitive category of personal data and is subject to stricter access controls than ordinary account data — see Section 16 (Data Security).

Wallet & Billing Information

We hold your AirTook Wallet transaction history (top-ups, consultation charges, refunds, subscription payments, and withdrawals), and, where relevant, your bank account details for payout (doctor earnings, Wellness Org earnings, or Fulfilment Partner settlement). We do not store raw card details — card numbers are processed and held entirely by Paystack, our licensed payment service provider, under its own security standards.

How You Use the Platform

• Device data — device type, operating system, app version, and, where you grant permission, push notification tokens.
• Usage data — pages and features used, interaction timestamps, and crash/error diagnostics.
• Approximate location — where needed to show nearby CarePoints or Fulfilment Partners, or to detect potentially fraudulent sign-ups (for example, an unusual number of accounts created from one network address).
• Connected device data — if you link Google Fit, Apple Health, or Withings, the fitness and health metrics those services share with us under your permission.

Face Data & Selfie Verification

To confirm you are who you say you are — protecting your medical records from impersonation — AirTook offers an optional identity check (for patients and doctors) that compares a live selfie against your National Identification Number (NIN) record. It is never required to use the app — you can skip it and continue.

• What we collect — a single selfie photo taken in the app, and your NIN (the number itself is never stored in full — only the last 4 digits and a salted one-way hash, used to detect duplicate submissions)
• How it's used — the selfie and NIN are sent to Dojah or SmileID, our identity-verification processors, which check the photo against the National Identity Management Commission (NIMC) record for a face match
• Shared with — the identity-verification processor only, solely to perform the match; they do not receive any other health or account data, and the selfie is never shared with doctors, advertisers, or any other party
• Storage — the selfie is stored privately, attached to your verification record. For patients, if the match succeeds, the same photo is also automatically set as your profile picture (visible to your doctors and any linked family members in the app) — you can change it any time in Settings
• Retention — kept for as long as your account is active, plus the same post-closure retention period as your other account data (see "Data Retention" below); you can request deletion at any time (see "Your Rights" below)

Cookies & Similar Technologies

On the AirTook website, we use strictly necessary cookies (for example, to keep you signed in and to remember your language or theme preference) and limited analytics to understand how the Platform is used and to improve it. We do not use third-party advertising cookies or sell any cookie-derived data. The mobile app does not use browser cookies, but uses comparable local device storage for the same session and preference purposes.

Sources of Your Information

• Directly from you — when you register, complete onboarding, book a consultation, log health data, or message Aira.
• Automatically — device, usage, and approximate-location data generated as you use the app.
• From a Guardian — if you are a Dependent in Family Hub, your information may be entered by a Guardian on your behalf.
• From an HMO or employer — membership or enrollment data, where you access AirTook under an HMO policy or a Corporate Account, limited to what is needed to verify coverage and billing.
• From a Practitioner or Fulfilment Partner — consultation notes, prescriptions, and lab or pharmacy fulfilment updates generated in the course of your care.

Nigeria Data Protection Act 2023 (NDPA)

AirTook processes your personal data in compliance with the Nigeria Data Protection Act 2023 and the guidelines issued by the Nigeria Data Protection Commission (NDPC). Our lawful bases for processing are:

• Contract — to provide healthcare services you have requested
• Consent — for optional features such as proactive Aira insights, connected-device sync, and identity verification
• Legal obligation — to comply with MDCN and Nigerian medical records regulations
• Vital interests — in emergency situations involving risk to life

Purpose of Processing

• Providing healthcare services and connecting you with licensed doctors
• Powering Aira's AI health guidance (your data stays within AirTook's secure environment)
• Processing wallet payments and tracking consultation fees
• Sending appointment reminders and follow-up check-ins (you can opt out in Settings)
• Verifying HMO coverage or Corporate Account eligibility, where applicable
• Detecting and preventing fraud, abuse, and account-security risks
• Compliance with regulatory requirements (MDCN, NDPC, Nigerian medical records law)
• Improving platform quality and safety

We do not use your health data for advertising or sell it to any third party.

How Aira Processes Your Data

Aira uses an AI language model (provided by OpenAI under a data processing agreement) to generate triage guidance, reminders, and certain automated actions from the messages and health data you share with it. Your Aira messages are not used to train OpenAI's general models.

Where Aira's own triage detects a possible emergency or safety concern during a conversation, that interaction is logged for human clinical-safety review, separately from your ordinary Aira history, so that a real safety signal is never only seen by an automated system. Aira does not make any final clinical decision about your care without a licensed Practitioner's involvement; it is a guidance and administrative tool, not an automated decision-maker for medical treatment.

Third Parties We Work With

• Doctors on AirTook — only the doctor assigned to your consultation sees your health data
• Paystack — payment processing (governed by Paystack's own privacy policy)
• OpenAI — Aira's AI engine (messages are sent under a data processing agreement; no data is used to train OpenAI models)
• Agora — real-time video and audio infrastructure for consultations and coaching calls
• Termii — SMS and WhatsApp notifications for appointment reminders and alerts
• Dojah / SmileID — identity verification (selfie + NIN face-match), only if you choose to verify your identity — see "Identity Verification" above
• Fulfilment Partners — verified pharmacies and laboratories, for orders you place through the Platform
• HMO payors and Corporate Accounts — limited coverage, eligibility, and billing data, never your clinical notes or Aira conversations, where you access AirTook under their sponsorship
• Our hosting provider — to store and run the Platform's infrastructure, under contractual confidentiality and security obligations
• Regulators and law enforcement — only where required by Nigerian law, a valid court order, or to protect someone's vital interests in an emergency

We do not sell your data to advertisers, data brokers, or any other third party.

Where Your Data Is Processed

Some of our processors (including OpenAI and our cloud hosting provider) may process data on servers located outside Nigeria. Where this happens, we rely on contractual safeguards with those processors — such as data processing agreements and, where applicable, standard contractual clauses — consistent with the cross-border transfer requirements of the NDPA 2023, and we work with processors that maintain comparable security and confidentiality standards to those required in Nigeria.

How We Protect Your Data

We use encryption in transit and at rest for sensitive data, role-based access controls so that only the staff or Practitioners who need to see a given record can access it, and audit logging of cross-patient record access by doctors, admins, or guardians. Payment card data never touches our own servers — it is handled entirely by Paystack. No system is perfectly secure, but we continuously review and improve these controls as the Platform grows.

If a data breach occurs that is likely to result in a risk to your rights or freedoms, we will notify the NDPC and affected users without undue delay, consistent with the NDPA 2023's breach-notification requirements.

How Long We Keep Your Data

Patient health records are retained for 7 years from the date of your last consultation, as required by Nigerian medical records regulations.

Account data (name, contact, wallet history) is retained for the duration of your account plus 7 years after closure.

Aira conversation history is retained for 12 months to provide continuity of care. You can clear your Aira history at any time from the app.

Where you delete your account, we delete or anonymise data that is not subject to a legal retention requirement; data we must keep (such as certain financial and medical records) is retained only for the mandated period and then securely deleted.

Rights Under the NDPA 2023

As a data subject under the Nigeria Data Protection Act 2023, you have the right to:

• Access — request a copy of all data we hold about you
• Correction — request that inaccurate data be corrected
• Deletion — request deletion of your personal data (subject to legal retention obligations)
• Portability — receive your data in a structured, machine-readable format
• Objection — object to processing based on legitimate interests
• Withdraw consent — turn off optional features like Aira insights in your profile settings

To exercise any of these rights, email privacy@airtook.com or use the "Request Account & Data Deletion" option in your profile. We will respond within 30 days.

Data About Minors

AirTook does not knowingly allow a child under 18 to register their own Independent account. A child's health profile is instead created and managed by a parent or legal guardian through Family Hub, as described in our Terms of Service — the child never holds their own login or credentials unless and until a Guardian chooses to "emancipate" them into an Independent account once they are old enough to hold one themselves. If we learn that a child has created an Independent account directly, we will convert it to a Family Hub Dependent profile or remove it, as appropriate.

Guardians & Dependents

Where you use Family Hub — AirTook's "Care Circle" model — a Guardian can view and manage the health data of a linked Dependent, scoped to the permissions ("care scopes") granted for that relationship — for example, appointments and medications, but not necessarily every category of data. Every action a Guardian takes on a Dependent's profile is attributed to that Guardian, not merged anonymously into the Dependent's own record, so there is always a clear account of who did what.

A Dependent's data is never shown inside the Guardian's own personal health profile, and a Guardian's own personal data is never shown while viewing a Dependent's profile — these are kept as separate "lenses" on purpose, so that managing a family member's care never leaks your own unrelated health information into their view, or theirs into yours.

Communications You Receive

We send transactional and care-related messages (appointment confirmations, reminders, follow-up check-ins, payment receipts, and safety notices) as a normal part of operating the Platform; these cannot be fully opted out of while you hold an active account, since they relate directly to the service you have asked us to provide. Where we send promotional content — such as a new feature announcement or a wellness tip not tied to your own care — you can opt out at any time from Settings, or via the unsubscribe link in that message, without affecting your access to the Platform itself.

Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you by email and in-app notice before a material change takes effect. Continued use of the Platform after that date constitutes acceptance of the revised Policy.