Privacy Policy

Last Updated: October 15, 2026

1. Introduction

TheHyWing ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, WhatsApp bot, and related services (collectively, the "Service"). TheHyWing is a climate-risk intelligence and preventive health platform that protects human health and livelihoods across multiple climate stressors. We operate globally and comply with applicable data protection laws in all jurisdictions where we serve users.

2. Data Controller

TheHyWing is the data controller responsible for your personal data. For data protection inquiries:

• Data Protection Officer: [email protected]
• General Support: [email protected]

3. Information We Collect

2.1 Personal Information

We collect information that you provide directly to us, including:

• Account Information: Email address, password (encrypted), and profile details
• Health Information: Occupation, work environment, climate exposure data, hydration records, vital signs, health conditions
• Agriculture Information: Crop types, livestock types, farming details (work_details field) — used solely to personalize Farm Intel climate risk assessments
• Location Data: Geographic location for weather-based alerts, agro-ecological zone detection, and optional automatic work journey detection (with your permission)
• Device Information: Device type, operating system, unique device identifiers

2.2 Automatically Collected Information

• App usage data and analytics
• Log data (IP address, timestamps, error logs)
• Weather API data for your location

3. How We Use Your Information

We use the collected information for:

• Service Delivery: Providing climate risk alerts, health monitoring, agricultural risk intelligence (Farm Intel), and medical consultations
• Personalization: Customizing alerts based on your work environment, health profile, and specific crops/livestock
• Livelihood Protection: Generating crop risk assessments, livestock welfare alerts, pest/disease warnings, and planting calendar guidance personalized to what you grow
• Safety: Sending critical climate health warnings and emergency notifications
• Communication: Sending service updates, password resets, and consultation reminders
• Analytics: Improving app performance and user experience
• Legal Compliance: Meeting regulatory and security requirements

3a. Why an Account and These Details Are Required

TheHyWing is a personalized safety and preventive-health service, not a general information app. The protection it provides — heat-strain and climate-risk scoring, hydration plans, symptom triage, doctor teleconsultations, safety-buddy check-ins, and employer/team safety features — cannot be delivered anonymously. Each of these is calculated against your own occupation, health vulnerability, and location, and is tied to a secure account.

For this reason we require an account and certain personal details to function. We rely on the following bases:

• Necessary for the service you request: Your occupation, work environment, and health profile are used directly to calculate the personalized risk warnings and guidance that are the core purpose of the app. Generic, non-personalized output would not protect you.
• Required by law: Because we facilitate consultations with licensed clinicians and process health data, we are legally required (under the Nigeria Data Protection Act 2023 and equivalent health-data rules) to maintain an identified account, record consents, and keep auditable medical records.
• Data minimization: We ask only for what is needed to deliver and personalize the service. Optional items (e.g. HealthKit signals, specific health conditions, crop/livestock details) can be skipped, and the app still works with safe default assumptions.

You may withdraw consent or delete your account at any time (Settings → Consents, or email [email protected]).

3b. Background Location and Automatic Work Journeys

If you explicitly enable Automatic work journey detection in Settings → Consents, TheHyWing collects location observations even when the app is closed or not in use. This background access is needed to detect when a logistics journey starts and stops without requiring you to keep the app open.

• Use: Location observations are used to calculate journey timing and distance and to support work-safety analytics.
• Retention: We retain derived journey details and your latest location for location-based services. We do not retain a GPS trail of the journey.
• Sharing: Your logistics company can view derived journey details such as timing and distance. We do not share the journey's GPS trail with the company.
• Your control: This feature is optional. You can stop background collection at any time by withdrawing Automatic work journey detection consent in Settings → Consents or by revoking location access in Android Settings.

3c. Optional Email Updates

TheHyWing Updates is a separate, optional mailing list for general explainers, product news and pilot opportunities. When signup is available, our linked Zoho Campaigns form collects your email address, any topic interest you choose to share, and records needed to manage your consent, confirmation, email delivery and unsubscribe preferences. No app account, health details, precise location or phone number is required.

We use this information with your consent to send the updates you request. We use Zoho Campaigns to manage this mailing list and deliver its emails; information submitted on its hosted form is processed by Zoho on our behalf. A topic preference does not create or lock a Health or Farm account, enable WhatsApp messaging, grant health-data consent or enrol you in a pilot. We do not automatically add existing product users to this list.

Confirm your email address to join. You can withdraw newsletter consent through the unsubscribe link in any newsletter, or request access, correction or deletion by contacting [email protected]. We retain mailing-list information while needed for your subscription; limited consent and suppression records may be retained as needed to honour opt-outs and legal obligations. A newsletter unsubscribe does not change your app account or its service notifications. We do not sell your subscriber information.

4. Health Information Protection

We take the protection of your health information seriously:

• All Protected Health Information (PHI) is encrypted at rest (AES-256) and in transit (TLS 1.2+)
• Access to health data is logged and monitored for compliance
• We implement HIPAA-aligned security practices
• Health data is only shared with licensed clinicians for consultations you authorize
• At signup you provide granular, separate consents for: Terms of Service, Privacy Policy, processing of health data, AI symptom assessment, WhatsApp messaging, and marketing — each of which can be reviewed or withdrawn in the app at any time (Settings → Consents).

4.1 Health Connect (Android) Disclosure

On Android, TheHyWing integrates with Health Connect to read selected wearable measurements only after you grant permission. We request read-only access and do not write any records to Health Connect.

Health Connect data types we request (read-only):

• HeartRate
• RestingHeartRate
• HeartRateVariabilityRmssd
• OxygenSaturation
• RespiratoryRate
• SkinTemperature

Why we access these data types: to compute your personalized physiological strain signal (heat/cold body stress), generate preventive actions, trigger high-risk alerts, and improve clinician decision-support during authorized consultations.

Minimum scope commitment: we request only the Health Connect data types required for the user-facing safety and preventive-health features described above. We do not request unrelated Health Connect permissions.

Sharing and limited use: Health Connect data is not sold and is not used for advertising, credit scoring, lending, or data brokerage. We only share health data with parties you authorize (for example, licensed clinicians in your consultation flow), or when legally required.

Your control: you can revoke Health Connect permissions anytime in Android Settings → Health Connect → App permissions → TheHyWing, and you can request deletion of your stored data from within the app (Settings → Consents) or by emailing [email protected].

4.2 Optional Movement-Aware Wellness

On supported app versions, Health users can separately enable movement-aware wellness in Privacy & Consents. With your permission, we use phone activity classifications from Android Physical activity or iOS Motion & Fitness, including background activity history, to adjust existing movement reminders. This feature does not add GPS tracking or Health Connect step, calorie or sleep access.

We receive only your latest activity summary and the time of a recent interaction with TheHyWing, not raw acceleration, a location trail or your use of other apps. The summary expires after two hours and is deleted by the next cleanup. A bounded activity history may be held locally on Android; expired history is cleared on the next callback or configuration. Turning the feature off or signing out clears its local history. Withdrawing movement consent deletes its server summary.

A stationary phone does not prove you are inactive, and a phone left behind or missing readings are treated as unknown. You can pause movement reminders using Already active or Phone left behind. The feature is general wellness support, not medical, emergency or fall monitoring. These activity summaries are not shared with employers or caregivers and are not sent to an AI service. Background updates depend on the operating system. Remote withdrawal stops server acceptance immediately; local collection stops at the next consent refresh or when its two-hour consent lease expires.

5. Information Sharing and Disclosure

We do not sell your personal information. We share data only in these circumstances:

• Healthcare Providers: Licensed clinicians during authorized consultations
• Caregivers: Only those you explicitly authorize
• AI Processing (OpenAI): Symptom descriptions are sent to OpenAI's API for AI-assisted health guidance. OpenAI processes this data under a Data Processing Agreement and does not use it for model training. No personally identifiable information (name, email, phone) is sent — only symptom text and anonymized health context.
• Service Providers: WeatherAPI.com / Open-Meteo (GPS coordinates only), Brevo (email delivery), Paystack (payments, PCI DSS compliant), Expo/EAS (push notification tokens), Render (cloud hosting)
• Legal Requirements: When required by law or to protect rights and safety
• Emergency Situations: To prevent serious harm to you or others

5a. Artificial Intelligence (AI) Transparency

6. Data Security

We implement industry-standard security measures:

• SSL/TLS encryption for all data transmission
• Encrypted database storage
• Secure authentication with JWT tokens
• Regular security audits and monitoring
• Access controls and audit logging

7. Your Rights

Depending on your jurisdiction, you have the following rights:

• Access: Request a copy of your personal data (GDPR, NDPA, CCPA, DPDP, POPIA)
• Rectification: Correct inaccurate or incomplete data (GDPR, NDPA, POPIA)
• Erasure / Deletion: Request deletion of your data (GDPR, NDPA, CCPA)
• Data Portability: Receive your data in machine-readable format (GDPR, DPDP)
• Restrict Processing: Limit how we use your data (GDPR, POPIA)
• Withdraw Consent: Revoke consent at any time (all jurisdictions)
• Non-Discrimination: Exercise rights without diminished service (CCPA)

To exercise any right, email [email protected]. We respond within 30 days.

8. Data Retention

We retain your information for as long as your account is active or as needed to provide services. Health records may be retained for longer periods to comply with medical record-keeping requirements.

9. Children's Privacy

TheHyWing is not intended for users under 18 years of age. We do not knowingly collect information from children under 18.

10. Data Breach Notification

In the event of a breach posing a risk to your rights, we will notify the relevant supervisory authority within 72 hours (GDPR/NDPA) and notify affected users without undue delay. Our breach response process includes:

• Detection & Assessment: Automated security event logging via our audit system identifies anomalous access patterns within minutes.
• Authority Notification: NDPC (Nigeria), relevant EU DPA, or other applicable authority notified within 72 hours of confirmed breach, including nature of breach, categories of data affected, approximate number of users, and remediation steps.
• User Notification: Affected users notified via email and in-app alert without undue delay, including what data was affected and recommended protective actions.
• Remediation: Encryption key rotation, forced token revocation, and access credential reset as appropriate.

11. International Data Transfers

Your data may be processed in countries other than your own. We use the following sub-processors:

We ensure appropriate safeguards for cross-border transfers including Standard Contractual Clauses (SCCs), Data Processing Agreements (DPAs) with each sub-processor, and encryption of all data in transit (TLS 1.2+) and at rest (AES-256). PHI (Protected Health Information) is encrypted before leaving our application layer and is never sent to sub-processors in plaintext.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via email or in-app notification. Continued use of the service after changes constitutes acceptance of the updated policy.

13. Jurisdiction-Specific Provisions

EEA (GDPR): Data portability, right to object, lodge complaints with your local DPA. USA (CCPA): Right to know, delete, opt out — we do not sell data. Nigeria (NDPA 2023): Consent-based processing, breach notification, correction/deletion. India (DPDP 2023): Consent management, data erasure, representative nomination.

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