Tamiin is a digital health insurance platform developed and operated by Innovastra Limited. We are committed to protecting personal data and supporting the responsible, secure and transparent processing of information across the health insurance and healthcare ecosystem.
This Privacy Policy explains how personal data may be collected, used, stored, shared and protected when individuals interact with Tamiin, including where the platform is used by Health Insurance Authorities, HMOs, insurers, TPAs, healthcare providers, employers and other authorised organisations.
This Privacy Policy applies to Tamiin websites, portals, applications, APIs and related digital services operated by Innovastra Limited.
Depending on the service being provided, Innovastra may process personal data on its own behalf or on behalf of an organisation using Tamiin. Where an organisation such as a Health Insurance Authority, HMO, insurer, employer or healthcare provider determines why and how personal data is processed, that organisation may be the relevant data controller, while Innovastra provides the technology and processes information on its behalf.
Depending on how Tamiin is used, information processed through the platform may include:
We seek to process only information reasonably necessary for the relevant service or lawful purpose.
Personal data processed through Tamiin may be used to support beneficiary enrolment and identity management; insurance eligibility and coverage verification; plan and benefit administration; provider assignment and network management; referrals and pre-authorization; claims submission, review and adjudication; capitation and other provider payments; premium administration; regulatory and operational reporting; fraud, waste and abuse detection; audit and compliance; customer support; security monitoring; interoperability with authorised healthcare systems; and improvement of the platform and its services.
We do not use personal data for purposes that are incompatible with the purpose for which it was collected unless permitted or required by applicable law.
Personal data is processed only where an appropriate lawful basis exists under applicable data protection law.
Depending on the circumstances, this may include consent, performance of a contract, compliance with a legal obligation, protection of vital interests, performance of a task carried out in the public interest, or another lawful basis recognised by applicable law.
Health and other sensitive personal data receive additional protection and are processed only where the applicable legal requirements for such processing are satisfied.
Tamiin may process health-related information where this is necessary to administer health insurance benefits, determine eligibility, process authorizations and claims, coordinate healthcare services, support payment, meet regulatory requirements or perform other authorised health insurance functions.
Access to such information is restricted according to authorised roles, responsibilities and legitimate operational requirements.
Personal data may be shared, where necessary and legally permitted, between authorised participants in the health insurance and healthcare ecosystem, including Health Insurance Authorities, HMOs, insurers, TPAs, healthcare providers, employers or sponsoring organisations, government or regulatory authorities, and authorised technology or service providers.
Information is shared only where there is an appropriate operational, contractual, regulatory or legal basis.
Tamiin does not sell personal data.
Innovastra implements administrative, technical and organisational safeguards designed to protect information processed through Tamiin against unauthorised access, disclosure, alteration, loss, misuse or destruction.
These measures may include role-based access controls, authentication controls, encryption, secure communications, logging and audit trails, access monitoring, backup and recovery procedures, infrastructure security and other appropriate security controls.
No electronic system can guarantee absolute security. We therefore continually assess and improve appropriate safeguards according to the nature and sensitivity of the information being processed.
Tamiin uses role-based permissions to restrict access to information according to authorised responsibilities.
User activities and important system events may be recorded in audit logs to support accountability, security investigations, regulatory compliance and detection of unauthorised activity.
Personal data is retained only for as long as reasonably necessary for the purposes for which it was collected and to satisfy applicable legal, regulatory, contractual, clinical, insurance, financial and audit requirements.
Retention periods may vary according to the type of information and the organisation responsible for the relevant records.
At the end of the applicable retention period, information may be securely deleted, anonymised or otherwise handled in accordance with applicable requirements.
Innovastra takes appropriate measures to ensure that personal data processed through Tamiin is hosted, accessed and transferred in accordance with applicable Nigerian data protection requirements.
Where personal data is transferred across jurisdictions, appropriate legal and organisational safeguards will be applied where required.
Tamiin websites and web applications may use cookies and similar technologies where necessary for authentication, security, session management, preferences, performance and operation of the platform.
Where required, users will be provided with appropriate information or choices regarding non-essential cookies. See our Cookie Notice for details.
Subject to applicable law and the circumstances of the processing, individuals may have rights relating to their personal data, including the right to request access to their personal data; correction of inaccurate or incomplete information; deletion where legally applicable; restriction of processing; objection to certain processing; withdrawal of consent where processing is based on consent; and data portability where applicable.
Individuals may also have the right to lodge a complaint with the relevant data protection authority.
Some rights may be subject to legal or regulatory limitations, particularly where information must be retained for healthcare, insurance, financial, regulatory, fraud prevention or legal purposes.
Where Innovastra is responsible for determining the purposes and means of processing, requests may be submitted directly to us.
Where Innovastra processes personal data on behalf of a Health Insurance Authority, HMO, insurer, healthcare provider, employer or another organisation, we may refer or transmit the request to the relevant organisation responsible for the information.
We may take reasonable steps to verify the identity and authority of a person making a request before disclosing or changing personal information.
Tamiin may process information relating to children and other dependants where they are enrolled as beneficiaries under a health insurance arrangement.
Such information is processed only for legitimate healthcare, insurance, regulatory or related purposes and is subject to appropriate safeguards.
Where consent is legally required, it must be provided by an appropriately authorised parent, guardian or other person.
Tamiin may use automated rules, analytics and other technologies to support activities such as eligibility verification, claims validation, risk identification, fraud detection, operational monitoring and decision support.
Where automated processing has significant legal or similarly significant effects on an individual, appropriate safeguards and human oversight will be applied where required by law.
Tamiin may integrate with authorised third-party systems and services to enable functions such as identity verification, healthcare information exchange, payment processing, communications, reporting and other operational services.
Third parties are expected to process information only for authorised purposes and subject to applicable contractual, security and data protection requirements.
Our websites or applications may contain links to external websites or services.
Innovastra is not responsible for the privacy practices of independent third parties. Users should review the privacy policies applicable to those services before providing personal information.
Innovastra maintains processes for identifying, assessing, managing and responding to personal data breaches and security incidents.
Where an incident is subject to regulatory or individual notification requirements, appropriate notifications will be made in accordance with applicable law.
Tamiin is designed to support responsible data processing within Nigeria's healthcare and health insurance ecosystem.
Innovastra processes personal data in accordance with applicable Nigerian privacy and data protection requirements, including the Nigeria Data Protection Act 2023, and other applicable regulatory obligations.
We may update this Privacy Policy periodically to reflect changes to Tamiin, our processing activities, regulatory requirements or applicable law.
When material changes are made, the updated policy will be published with a revised Last Updated date. Where appropriate, additional notice may be provided.
Continued use of the relevant services following an update will be subject to the updated Privacy Policy, to the extent permitted by applicable law.
If you have concerns about how your personal data is being processed, you may contact our Data Protection Officer using the details below.
We will review privacy-related complaints and take appropriate steps to address them in accordance with applicable requirements.
You may also lodge a complaint with the Nigeria Data Protection Commission (NDPC) where you believe your rights under applicable Nigerian data protection law have been infringed.
For privacy enquiries, requests or complaints relating to Tamiin, please contact:
Innovastra Limited
Tamiin — Health Insurance Platform
Data Protection Officer (DPO)
Email: dpo@innovastra.com
Telephone: +234 907 009 1926
Address
Plot 24, Block 14
Kola Adeyina Close
Lekki Phase 1
Lagos, Nigeria
Tamiin