DRAFT v0.1 — 11 November 2026 — Draft for discussion. Not legal advice. To be reviewed by Nigerian legal counsel before signature or publication.
Published by: {{COMPANY_LEGAL_NAME}}, {{COMPANY_ADDRESS}} — operator of Velnova Health (velnovahealth.com). Contact: {{CONTACT_EMAIL}}.
This notice explains how personal data is handled on the Velnova Health websites and hospital portals. Velnova Health is a cloud platform that hospitals in Nigeria use for medical imaging, reporting and (where subscribed) medical records.
For patient and clinical data, your hospital is the data controller and we are its processor: the hospital decides why and how your data is used, and we store and process it only on the hospital's instructions, under a data-processing agreement and the Nigeria Data Protection Act 2023 (NDPA). Questions about your medical records, and requests about your data, should go to your hospital in the first instance — we will always help the hospital answer them.
We are the controller only for the limited data described in section 2(c) below (our own business and platform-operation records).
(a) Hospital staff and clinician accounts (processed for the hospital, as processor): name, work email, phone number, role, hospital tenancy, sign-in and session records (including IP address and device information), and activity/audit logs. Purposes: providing the portal, securing accounts, attributing clinical actions (for example, who signed a report), and supporting the hospital. Legal basis: the hospital's instructions and its own legal bases as controller (performance of its healthcare functions, legal obligations, and legitimate interests in safe record-keeping).
(b) Referring doctors using secure report links (processed for the hospital, as processor): the fact a link was sent to you, and a log of each time the link is opened (time and IP address). Purposes: delivering the report the hospital asked us to share with you, and keeping an access record for the hospital. Links expire and can be revoked by the hospital.
(c) Patients using report verification (we act for the hospital; the verification register itself is operated by us as described here): when you verify a report — at velnovahealth.com/verify or a hospital's own verify page — we record the verification code you enter, the time, and technical details of the request. The verification register holds only: the verification code, a cryptographic hash of the report, the hospital's name, the examination name and study date, the signing radiologist's name and registration (MDCN) number, the report's version and status, and when it was signed. It does not hold your images or the text of your report, and verification never displays the full report text. Purposes: letting anyone holding a printed report check that it is genuine and current — including after a hospital has left the platform, so paper reports remain verifiable. Legal basis: legitimate interests in preventing forged medical reports, and the hospital's record-keeping obligations.
(d) Patients generally: your imaging studies, reports and contact details are held for your hospital as in section 1. If your hospital has asked us to send you a "report ready" message, your phone number is used for that message (WhatsApp, SMS or email). The message contains no clinical information — only that your report is ready, where to collect it, and your verification code. You will only be sent these messages if you agreed to them at the hospital (see the hospital's consent form); tell the hospital if you want them stopped.
(e) Our own records (we are controller): enquiries sent to {{CONTACT_EMAIL}}, hospital customer/billing contacts, and platform security logs. Purposes: responding to enquiries, running the business, and keeping the platform secure. Legal basis: legitimate interests and, for billing, legal obligations.
We do not sell personal data. Data is shared only:
[Hosting location and any cross-border transfer position to be inserted once hosting is decided — see the open-decisions list in the pack index.]
Patient and clinical data is kept and deleted according to the platform's Retention & Exit Policy, which forms part of our agreement with each hospital; the verification register is kept for the same period as the report it vouches for, so that printed reports remain verifiable. Account and security records are kept for as long as needed for security and audit purposes under the same policy.
Hospital data is segregated per hospital, access is by individual accounts with role-based permissions, access is audit-logged, and data is encrypted in transit and at rest. Our own platform administrators cannot view images or report content — their access is limited to operational metadata such as counts and statuses.
You have rights to be informed, to access your data, to have inaccuracies corrected, and — subject to legal limits — to object to or request erasure of your data, and to complain to the Nigeria Data Protection Commission. For patient and clinical data, please direct requests to your hospital, which decides them as controller; medical records are subject to mandatory retention periods and legal holds, which the hospital will explain if they affect your request. For data where we are the controller (section 2(e)), contact us at {{CONTACT_EMAIL}} and we will respond within the time the NDPA allows.
We will post changes to this notice at velnovahealth.com with the effective date. This version is effective {{EFFECTIVE_DATE}}. Questions: {{CONTACT_EMAIL}}.
Draft v0.1 · 11 November 2026 · Placeholders in {{double braces}} to be settled before publication.