Privacy and Cookie Policy For Kulawa.ng
This privacy and cookie policy applies to the website: https://www.kulawa.ng (“kulawa.ng”)
Kulawa.ng is managed by the PharmAccess Foundation (“PAF”), Nigeria.
In this privacy policy we describe:
- which of your personal data we collect and process via the cookies we use on kulawa.ng,
- how we handle your personal data and
- what rights you have in that context.
1. Personal data and cookies
Personal data is any data that can identify a natural person (directly or indirectly). Personal data can be a name or telephone number, but also, for example, a date of birth or e-mail address. At the moment Kulawa.ng only collects personal data through cookies.
A cookie is a small piece of data stored on the user’s computer by the web browser while browsing a website. The main purpose of a cookie is to identify users and possibly prepare customized web pages or to save site login information for you. In addition, a small text file is sent to your browser, so that the browser is automatically recognized when you visit kulawa.ng again. Cookies can collect personal data related to the use of kulawa.ng, such as which pages have been visited and your IP address. Since Kulawa.ng contains sensitive data about health, please note that it may be possible that we process your health data based on your click behavior.
We use the following cookies:
A. Functional cookies
These cookies are necessary for kulawa.ng to function. Kulawa.ng uses the following functional cookies:
| Cookie | Target | Retention period |
| These cookies are created when the cookie bar on kulawa.ng is closed and they remember your choice for a subsequent visit. | 100 days | |
| These cookies are created when closing the exit questionnaire on kulawa.ng and remember your choice for a subsequent visit. | 1 year | |
| In these cookies, the settings are saved for reading page content on Kulawa.ng. | 4 days | |
| These cookies are necessary for the ‘remember me’ function when forwarding by e-mail | 1 month |
PAF has a legitimate interest to process this data for the above purposes, because the website will not function without this data.
B. Strictly Analytical Cookies
These cookies collect personal data, such as your IP address and we use this for the following purposes:
| Cookie | Target | Retention period |
| This cookie determines whether you are a new or a returning visitor. | 12 months | |
| This cookie is used to see through which referrer someone entered the website. | 6 months | |
| This cookie determines which pages you have visited on Kulawa.ng. | Duration of the visit to our website |
PAF considers the protection of privacy a very important right. Certainly, we have taken measures to limit the traceability of visitors to our website as much as possible.
PAF has a legitimate interest in processing your data for the above purposes, because PAF cannot optimize the website for you without this data.
C. Tracking Cookies
| Cookie | Target | Retention period |
| Session cookies are set when a user logs in to the Kulawa site until the user logs out | 15 Days | |
| This stores userdata cookies which areany kind of information from page to page before the user and it remains on the browser. | Duration of the visit to our website | |
| Other session cookies created on theKulawa website contain information that is stored in a temporary memory location and then subsequently clear off when user logs out or when the browser is closed just to identify tasks for every user on the platform | Duration of the visit to our website |
If you do not want the Kulawa website to place any cookies at all, you can adjust the settings of your Internet browser and completely block the placing of cookies. You can click on “help” in the browser menu to find out how to do this for the browser on your computer. By removing all cookies, it may be possible that not all parts of Kulawa.ng will work.
2. Who do we share personal data with
PAF mayengage third parties in the performance of its services
For example, Kulawa.ng is developed and hosted by a third party. The following third parties are subprocessors forPAF:
- Kinsta.com – https://kinsta.com/legal/privacy-policy/ – webhost
PAF makes agreements with such subprocessors to ensure that your personal data is adequately protected by these parties.
PAF will not provide your personal data to a third party that has not been engaged by PAF to enable the intended use of the Kulawa.ng website by the user, unless PAF is obliged to do so by law.
Your Personal data will never be shared with third parties for commercial purposes
Websites Third Parties
Kulawa’s website may contain links to other websites, such as news sites, social media, international organizations, other non-governmental organizations or other relevant entities. This Privacy Statement does not apply to any hyperlinks or content of third-party websites shown on or linked to our website. Kulawa does not monitor or control the information collection or privacy practices of these or any other third parties and is therefore not responsible for the content, the accuracy, completeness, usefulness of information or the products or services offered by third party websites.
3. Security of personal data
PAF has taken appropriate technical and organizational measures to protect your personal data against loss or another form of unlawful processing.
We may change this privacy policy from time to time by posting an update of this version here. To stay informed, we recommend that you visit these pages regularly. This privacy policy has been last modified on 14th May, 2021.
4. Your rights
You have the right to request us to:
- give access to your personal data;
- have your personal data supplemented, corrected or deleted;
- object to the processing of your personal data;
- restrict your personal data; and / or
- provide your personal data to you or to a third party.
These rights are not absolute. We will assess your request in accordance with the Nigerian Data Protection Regulation 2019. We will provide you with information about the actions we have taken in response to your request as soon as possible, but in any case within one month of receiving your request. We can extend this period by two months due to the complexity of your request or the number of requests we receive. We will inform you in that case.
You have the right to file a complaint with the National Information Technology Development Agency (NITDA) which is Nigeria’s foremost agency responsible for regulating data privacy and protection at any time.
You can contact our Data Protection Officer at 0806-110-6370, and at the followingemail address: privacyofficer@Pharmaccess.org