Privacy Policy
How we collect, use, and protect your personal and health data
This Policy applies to all users in Cameroon, across African Union member states, and EU/EEA users. Where jurisdictional requirements conflict, the stricter standard applies.
Introduction and Identity of the Data Controller
Ukuqala Health Technologies (“Ukuqala”, “we”, “us”, or “our”) operates a telemedicine and clinical decision-support platform. We provide digital health services connecting licensed physicians with patients across Africa, with primary operations in Cameroon.
This Privacy Policy describes how we collect, process, store, share, and protect personal data — including sensitive health data — in connection with the Platform. It applies to all users: physicians, patients, clinic administrators, and visitors.
Scope and Territorial Applicability
This Policy applies to users across the following jurisdictions:
- Cameroon: Law No. 2024/017 (Personal Data Protection) · Law No. 2010/012 (Cybersecurity)
- African Union member states: Malabo Convention (entered into force 8 June 2023)
- Nigeria: Nigeria Data Protection Act (NDPA) 2023
- South Africa: Protection of Personal Information Act (POPIA) 2021
- Kenya: Data Protection Act 2019
- Ghana: Data Protection Act 2012
- Senegal / Côte d'Ivoire: National data protection legislation
- EU / EEA users: GDPR (EU) 2016/679 · ePrivacy Directive 2002/58/EC
Data We Collect
Identity & Contact Data
- Full legal name, professional title, medical license number
- National ID (for physician verification)
- Email address, phone number, physical address
- Profile photograph
Authentication Data
- Encrypted password credentials
- OTP logs via SMS (Africa's Talking)
- Two-factor authentication event logs
- Session tokens (never stored in plaintext)
Physician Credential Data
- Medical degree and specialty certificates
- ONMC / national medical council registration
- Hospital/clinic affiliation letters
- Annual practice certificates, CME records
Health & Clinical Data (Patients)
- Blood group, allergies, chronic conditions
- Vital signs (BP, HR, temp, O₂ saturation, glucose, BMI)
- SOAP clinical notes, ICD-10 diagnoses
- Prescriptions, referrals, medical certificates
- AI symptom intake records, RSE risk scores
Financial & Transaction Data
- Consultation fee payment records
- Mobile money transaction references (MTN, Orange)
- Invoice and receipt data
- No full payment card numbers are stored
Technical & Usage Data
- IP addresses, browser type, device identifiers
- Pages visited, features used, session duration
- Error logs and crash reports
Legal Basis for Processing
We process personal data only when we have a lawful basis:
| Data Category | Legal Basis |
|---|---|
| Account registration and identity | Contract performance |
| Health and clinical data | Explicit consent + health care provision necessity |
| Physician credential verification | Legal obligation + legitimate interest |
| Payment processing | Contract performance |
| Platform security, fraud prevention | Legitimate interest |
| AI-assisted clinical features | Explicit consent + health care provision |
| Analytics and platform improvement | Legitimate interest (anonymised only) |
| Regulatory reporting (notifiable diseases) | Legal obligation (MINSANTE, WHO IHR) |
For sensitive health data, we rely on explicit written or digital consent combined with the necessity for health care provision, as required under Cameroon Law 2024/017, GDPR Article 9, and equivalent African data protection statutes.
How We Use Your Data
For Patients:
- Enabling telemedicine consultations with verified physicians
- Maintaining your longitudinal medical record
- Generating prescriptions, referrals, and medical certificates
- Sending appointment reminders and health alerts
- Enabling AI-assisted symptom intake and risk stratification
- Facilitating QR-based record sharing with authorised providers
For Physicians:
- Verifying credentials against national medical council registries
- Enabling clinical documentation (notes, prescriptions, referrals)
- Facilitating doctor-to-doctor case collaboration
- Providing AI-powered clinical decision support
- Processing consultation fee payments
- Supporting MINSANTE regulatory compliance
Data Sharing and Third-Party Processors
We do not sell personal data. We share data only under strict contractual data protection obligations:
| Recipient | Purpose | Data Shared |
|---|---|---|
| Agora RTC | Video consultation infrastructure | Session metadata only |
| Mistral AI | Clinical AI suggestions | Anonymised symptom data; no patient identifiers |
| Africa's Talking | SMS-based OTP and alerts | Phone number, OTP token |
| MTN Mobile Money / Orange Money | Payment processing | Transaction amount, phone number, reference ID |
| Supabase | Database hosting and authentication | Encrypted patient records |
| ONMC (Cameroon) | Physician license verification | License number and name |
| MINSANTE / WHO | Mandatory disease reporting | Anonymised/aggregated epidemiological data only |
Data Retention
| Data Category | Retention Period | Legal Basis |
|---|---|---|
| Medical records and clinical data | 10 years from last consultation | Law 2010/012; professional standards |
| Communications metadata (SMS, calls) | 10 years | Law 2010/012 Art. 41 |
| Financial / payment records | 7 years | Tax and audit obligations |
| Physician verification documents | Account duration + 5 years | Regulatory compliance |
| Inactive account data | 3 years after last activity | Legitimate interest |
| AI interaction logs | 2 years (anonymised after 6 months) | Platform safety |
| Technical / server logs | 12 months | Security and fraud prevention |
Your Data Rights
| Right | Description | How to Exercise |
|---|---|---|
| Access | Obtain a copy of all personal data we hold | Email [email protected] |
| Rectification | Correct inaccurate or incomplete data | Account settings or email request |
| Erasure | Request deletion (subject to retention obligations) | Written request to [email protected] |
| Portability | Receive data in machine-readable format | Written request; 30-day delivery |
| Restriction | Limit processing while a dispute is resolved | Written request |
| Withdraw Consent | Withdraw consent at any time | Account settings or email |
| Complaint | Lodge a complaint with supervisory authority | See Section 14 of full policy |
All requests are responded to within 30 days. We may require identity verification before fulfilling requests.
Security Measures
Encryption at rest
AES-256 for all stored health data
Encryption in transit
TLS 1.3 for all transmissions
Authentication
Mandatory 2FA for all physician accounts
Access controls
Role-based access (RBAC)
Audit logging
Immutable trails on all record access
Penetration testing
Regular third-party security assessments
Data Breach Notification
In the event of a personal data breach, we will notify affected individuals within 72 hours of becoming aware, and we will notify the relevant data protection authority as required by applicable law.
To report a suspected security incident: [email protected]
Supervisory Authorities and Complaints
Cameroon
Autorité de Protection des Données à Caractère Personnel (under Law 2024/017)
Nigeria
Nigeria Data Protection Commission (NDPC)
South Africa
Information Regulator — inforegulator.org.za
Kenya
Office of the Data Protection Commissioner (ODPC)
Ghana
Data Protection Commission (DPC)
Senegal
Commission de Protection des Données Personnelles (CDP)
EU / EEA users
Competent supervisory authority in your EU member state
We encourage you to contact [email protected] first — we are committed to resolving concerns directly.
This policy was prepared in accordance with Cameroon Law No. 2024/017, Law No. 2010/012, the African Union Malabo Convention, GDPR (EU) 2016/679, and applicable national data protection statutes across African jurisdictions. Effective 1 May 2026 · Version 1.0