HEALTHCARE LEADERSHIP ACADEMY LIMITED BY GUARANTEE:
By accessing our website (the “Website”) or our Learning Management System (“LMS”), (together, “Platforms”), or by accepting our Terms and Conditions (the “Terms”) or any other terms that incorporate this Privacy Policy by reference, you agree on behalf of yourself and any organization that you represent (together, “you” or the “User”) that you have read and understood this Privacy Policy and that you consent to the collection, use, and sharing of information (subject to the terms herein) for the purpose of providing information and services aimed at improving the capacity of healthcare leaders in Africa who excel in governance and the provision of quality services through the delivery of context specific capacity development programmes which address identified skill gaps across health systems, amongst others (the “Services”).
This Privacy Policy describes the User’s privacy rights regarding HLA’s collection, use, storage, sharing and protection of a User’s personal information on either of the Platforms. If a User creates a username, identification code, password or provides any other piece of information as part of the Platforms’ access security measures, such information will be treated as confidential, and will not be disclosed to any third party. HLA reserves the right to disable any User identification code or password, whether chosen by a User or allocated by the Platform at any time, if in HLA’s opinion, a User has failed to comply with any of the Terms (including this Privacy Policy). If a User is aware or suspects that anyone other than his/herself is aware of a User’s security details, kindly notify HLA as soon as possible via the following address: info@hlaafrica.org.
The use of the Platforms and the Services rendered thereon require that we collect information received via the use of a computer, mobile phone or other electronic access device by a User. The automatically collected information includes, but is not limited to, data about the pages accessed by a User, computer internet protocol (“IP”) address, device identification or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the Platforms, referral uniform resource locator (“URL”), advertising data, standard web log data, still and moving images.
The Platforms can be visited without revealing any personal information. However, when registering on the Platforms, where applicable, the Platforms may collect the following information, including, but not limited to, contact address, email address, phone number, payment information, payment card details, information on web form, survey responses account update information, correspondence with the Platform support services and communication with HLA, amongst others. HLA will use this information to reply to your inquiries, to provide you with requested products and services, set up your member's account, and contact you regarding new products and services. In addition, the Platforms may also collect information about a User’s enquiries and activities on the Platforms to help improve the User’s experience.
By accessing the services on the Platforms, or using our services, content, features or functions offered on our Platforms or visiting any of our offices for official or non-official purposes and voluntarily providing us with the requested personal information, you consent to the collection and use of the information in accordance with this Privacy Policy. Your consent can be withdrawn at any time by sending a request to that effect to the contact information supplied above. If you do not consent to the collection, use or disclosure of your personal information as outlined in this Privacy Policy, please do not provide any personal information on either of the Platforms. Information about a User provided to other third parties or websites and used by such parties are not controlled by HLA and HLA is therefore not liable for how such information are used.
HLA collects a User’s personal information to provide an efficient and secure User experience and may retain such personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Information gathered on the Platforms for each User may be used to:
You are required to familiarise yourself with this Privacy Policy and ensure that the information you provide to us is complete, accurate and up to date.
Cookies are small files placed on a User’s computer hard drive to enable a website identify a User’s computer as different pages are viewed. Cookies also allow websites and applications to store a User’s preferences in order to present content, options or functions which are specific to a User. Like most interactive websites, the Platforms use cookies to enable the tracking of a User’s activity for the duration of a session. The Platforms use only encrypted session cookies which are erased either after a pre-defined timeout period or once a User logs out of the Platforms and closes the browser. Session cookies do not collect information from the User’s computer. They will typically store information in the form of a session identification that does not personally identify a User.
During a User’s interaction on the Platforms, a User’s data such as full name, contact details, or other similar details may be provided to third parties for the purpose of performing the Services. Where a User’s data needs to be transferred to another country, such country must have an adequate data protection law before same may be transferred by HLA to such country. In the event HLA needs to send a User’s data to a country without an adequate data protection law, such User’s consent will be sought. Information provided on the Platform is protected using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the security measures used include firewalls and data encryption, physical access controls to the Platforms’ data centres, and information access authorization controls. HLA may also share a User’s personal information in compliance with national or international laws; crime prevention and risk management agencies and service providers.
The security of your personal information is central to us. We follow global industry standards to protect the personal information submitted to us, both during receipt and processing of your information; although no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Nonetheless, any personal information you provide to us on either of the Platforms is kept on secure servers. We use security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of the personal information. To help us protect your privacy, you should maintain the secrecy of the logon ID and password you may have set up in connection with your submissions on the System and our website in general.
To prevent unauthorized access to a User’s information, HLA has implemented strong controls and security safeguards on the Platforms. The Platforms use Secure Sockets Layer/Transport Layer Security (“SSL/TLS”) to ensure secure transmission of a User’s personal data. A User will see a padlock symbol in the URL address bar once successfully logged onto the Platform. The URL address will also start with https:// indicating a secure webpage. SSL applies encryption between two points such as a User’s computer and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission.
HLA has links to other websites or Organisations on its website. HLA is not responsible and has no control over websites outside its domain. We do not monitor or review the content of other party’s websites which are linked from our website or media platforms. Opinions expressed or materials appearing on such websites are not necessarily shared or endorsed by us, and HLA should not be regarded as the publisher of such opinions or materials. Please be aware that we are not responsible for the privacy practices, or content of these sites. We encourage our Users to take note of when they leave our site and ensure they read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to our Platforms or accessed through our Website, before disclosing any personal information to them. HLA will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information.
In the event that you use another website which has been integrated with the Platforms’ application programming interface (API) (the “Third Party Site”), you acknowledge and agree that you have carefully read and understood the terms of use (including the privacy policy) of the Third Party Site. You further acknowledge and agree that HLA is authorized to share any data which you enter on the Platforms with Third Party Sites, subject to applicable laws of the Federal Republic of Nigeria. Provided always that HLA shall not bear any liability for data shared by Users with Third Party Sites or such other platforms accessed through the use of the Platforms
A User’s information is regarded and will be held as confidential. A User has the right to request sight of, and copies of any and all personal information on the Platforms. A User’s role in fulfilling confidentiality duties include, but are not limited to, adopting and enforcing appropriate security measures as HLA will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from a User’s disclosure of personal information to third parties.
HLA is required to comply with the NDPR and other relevant regulations regarding reporting requirements in relation to data breaches and report any personal data breach where there is a risk to the rights and freedoms of a User. Where a personal data breach results in a high risk to a User, such a User also has to be notified unless subsequent steps have been taken to ensure that the risk is unlikely to materialise, security measures were applied to render the personal data unintelligible (e.g. encryption) or it would amount to disproportionate effort to inform the User directly. In the latter circumstances, a public communication must be made, or an equally effective alternative measure must be adopted to inform such a User, so that he/she can take any necessary remedial action.
HLA has placed procedures around the Platforms to deal with any suspected personal data breach and will notify a User or the relevant regulator (where legally required to do so). Any suspected breach of personal data of a User will be remedied with one (1) month from the date of the report of the breach. All evidence relating to a personal data breach should be preserved to enable HLA maintain a record of such breaches, as required by the data protection laws. HLA will not be responsible for any personal data breach which occurs as a result of:
In the event of a breach of this privacy policy by HLA in relation to the collection, processing and/or use of your personal information, you are required to notify us via an email sent to info@hlaafrica.org stating the nature of the breach and giving us a period of at least seven (7) days to remedy such breach accordingly.
Where we fail to remedy such breach within seven (7) days, you may report the suspected case of breach of our privacy policy to the National Information Technology Development Agency and pursue any remedies permitted under applicable law.
If you have any questions about our use of your personal information, want to exercise your rights (to correct, delete, or restrict use) in relation to your personal information/data or want to lodge a complaint in relation to the collection and/or use of your personal information for purposes and/or in ways outside the purview of this privacy policy, you can contact our data privacy team through the following email: info@hlaafrica.org, but if you prefer you can also write to us at: 22, Okotie Eboh Close, Off Awolowo Road, Ikoyi, Lagos.
You may instruct us at any time not to use your personal information covered by this Privacy Policy to provide you with information on our products and services or not to provide your information to affiliate companies and/or third parties who/which may have other services may be of interest to you, by sending an email to info@hlaafrica.org to unsubscribe from our services.
Please note that (i) the opt-out process may take up to twenty-four (24) hours to complete, and (ii) even after such opt-out process is completed, your personal information may continue to be shared with our affiliates (including affiliated websites under common ownership or control) and designated service providers.
You can also update your personal information however necessary. Please note that if you exercise your choice in this manner, you will continue to receive communications concerning available products and services and in response to any requests for information by you.
HLA reserves the right to change this Privacy Policy at any time without notice to Users. In the event HLA modifies this Privacy Policy, we may contact you via email and provide you with notice of the change and a link to review the new privacy policy. However, you have the responsibility to keep abreast of changes to our Policies as updated on this page from time to time.
This Privacy Policy is made pursuant to the NDPR provisions and any other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention applicable in Nigeria, such provision shall be subject to the overriding law, regulation or convention.
