Privacy Policy

Skeepy is Nigeria's first pet Health Maintenance Organisation (HMO). We provide affordable pet healthcare coverage plans that enable pet parents to access veterinary services at our network of partner clinics across the country. We also operate the Skeepy National Pet Database (NPD), a free digital registry that gives every registered pet in Nigeria a unique identification number.

This Privacy Policy applies to all information collected through:

• Our website at skeepy.co and all its pages
• HMO plan enrolment, management, and claims processing
• The National Pet Database (NPD) registration and lookup services
• The Skeepy Cheerleader (referral partner) programme
• Partner clinic onboarding and management
• Customer support communications via email, phone, and WhatsApp
• Any other services provided by Skeepy Pet Solutions Limited

Personal Information

When you create an account, enrol in an HMO plan, register a pet on the NPD, or sign up as a Cheerleader or partner clinic, we collect the following personal details:

• Full name (first name and last name)
• Email address
• Phone number
• Residential address
• City and state of residence
• Emergency contact information (where applicable)

Pet Information

To provide pet healthcare coverage and maintain the National Pet Database, we collect information about your pet(s), including:

• Pet name
• Pet type (dog or cat)
• Breed
• Gender
• Date of birth / age
• Colour / markings
• Weight
• Medical history (including pre-existing conditions, vaccination records, and veterinary notes)
• Pet photographs (uploaded for identification on the NPD and HMO profiles)
• Microchip number (if applicable, for NPD registration)
• Spay/neuter status

Account & Identification Data

When you use our services, we generate and maintain the following identifiers tied to your account:

• HMO ID - A unique identifier in the format SKEEPYHMO-XXXXXX, assigned when you enrol in a pet HMO plan
• NPD ID - A unique identifier in the format SKNPID-NG-XXXXXX, assigned when you register a pet on the National Pet Database
• Cheerleader referral codes (for referral programme participants)
• Account login credentials (email and securely hashed password)
• Plan and subscription details (plan tier, billing cycle, enrolment date, renewal dates, coverage status)

KYC (Identity Verification)

Before you pay a clinic with Skeepy Pay, we verify who you are. For this we collect:

• Your legal name and date of birth, as on your NIN or BVN record
• Your NIN or BVN, stored encrypted
• Photographs of your face, taken from a few angles while you follow on-screen prompts. These are biometric data, which the Nigeria Data Protection Act treats as sensitive personal data
• Your home address, and a utility bill or similar document if you give one
• A bank account in your name: the bank, the account number (stored encrypted) and the name the bank holds for it
• A record of your consent: when you gave it, and the device and IP address you used

We use these details only to confirm your identity, to keep your plan from being used by anyone else, and to prevent, investigate and pursue fraud, including by sharing them with the police or a court where the law allows. We collect them with your explicit consent, which you give on the KYC page, separately from this policy.

Skeepy Camera: photos, time and location

When you pay a clinic with Skeepy Pay, you take a photo of your pet, and of the bill, with Skeepy Camera in your dashboard. Each photo records the date and time it was taken and, if you allow it in your browser, where your phone says it was taken. The time and place are also printed on the photo.

We use them to confirm that the photo was taken at the clinic, at the visit, and to prevent and investigate fraud. We compare the place with earlier photos taken at the same clinic and with the place Skeepy's own team records when it visits the clinic. Your location is read only while Skeepy Camera is open; we never track it at any other time. If you do not allow location, the photo is still accepted, and the payment may be checked by a person before it is made.

Payment Information

All payments on Skeepy are processed securely by Paystack, a PCI DSS-compliant payment processor. When you make a payment, the following applies:

• Your card details (card number, expiry, CVV) are collected and processed directly by Paystack - we never see, store, or have access to your full card numbers
• We store a Paystack authorisation token for recurring subscription payments
• We maintain records of transaction references, amounts, payment dates, and payment status for billing and reconciliation purposes
• We store the last four digits of your card and card type for your reference in your account

Usage Data & Technical Information

When you visit our website or use our services, we may automatically collect:

• IP address
• Browser type and version
• Operating system
• Device type (mobile, desktop, tablet)
• Pages visited and time spent on each page
• Referring website (how you found us)
• Date and time of access

This data helps us understand how our website is used, diagnose technical issues, and improve the user experience.

Communication Data

When you contact us or we contact you, we may collect and store:

• Emails sent to and received from our support team
• WhatsApp messages exchanged with our support line
• Phone call records (date, time, and duration - calls may be recorded for quality purposes)
• Support ticket details and correspondence
• Feedback and survey responses

Service Delivery

• Process HMO subscriptions and payments - enrol you in a plan, process recurring payments, manage billing cycles, and handle plan upgrades or cancellations
• Manage pet healthcare coverage and claims - verify your coverage at partner clinics, process veterinary claims, track benefit usage against plan limits, and manage wait periods
• Maintain the National Pet Database (NPD) - create and manage your pet's digital profile, generate unique NPD IDs, and enable pet lookup and identification services
• Administer the Cheerleader programme - track referrals, calculate commissions, and process payout requests
• Onboard and manage partner clinics - verify clinic information, assign clinic categories, and process clinic payouts for claims

Communication

• Send transactional emails - plan confirmation, payment receipts, renewal reminders, claim updates, coverage status changes, and account notifications
• Send service updates - notify you about changes to your plan, new partner clinics in your area, or important service announcements
• Respond to enquiries - address your questions, complaints, and support requests via email, phone, or WhatsApp
• Send NPD notifications - registration confirmations, pet profile updates, and lost pet alerts (if enabled)

Service Improvement & Analytics

• Improve our services - analyse usage patterns, identify popular features, and enhance the user experience on our website and dashboards
• Fraud prevention - detect and prevent fraudulent claims, duplicate accounts, or suspicious activities
• Compliance and reporting - fulfil regulatory obligations, maintain financial records, and produce aggregate statistical reports
• Research and development - understand pet healthcare trends in Nigeria to develop better coverage options and services (using anonymised, aggregate data only)

Legal Basis for Processing

Under the NDPR and NDPA, we process your personal data on the following lawful bases:

• Consent - You have given clear consent for us to process your personal data for specific purposes (e.g., marketing communications, NPD public search visibility)
• Contract - Processing is necessary for the performance of our service agreement with you (e.g., managing your HMO subscription, processing claims)
• Legitimate interest - Processing is necessary for our legitimate business interests (e.g., fraud prevention, service improvement), provided these interests do not override your fundamental rights
• Legal obligation - Processing is necessary for compliance with Nigerian law

Partner Veterinary Clinics

When you visit a Skeepy partner clinic for treatment, we share the following information with the clinic to verify your coverage and process claims:

• Your name and HMO ID. Never your phone number, email address or home address
• Your pet's name, type, breed, and basic profile
• Your plan tier and current coverage status
• Relevant benefit limits and available coverage amounts
• Wait period status for applicable benefits

Clinics are bound by their provider agreements with Skeepy to use this information solely for the purpose of providing veterinary services and processing claims. They may not use your information for marketing or any other unrelated purpose.

Identity Verification

Your KYC details are seen only by the Skeepy team who verify them. They are never shown to clinics. We send your bank and account number to Paystack, which returns the name the bank holds for the account. We may also check your NIN or BVN and your face photos with a licensed identity verification provider in Nigeria; if we do, the provider processes them only to give us the result.

Payment Processor (Paystack)

We share necessary transaction details with Paystack to process your payments. Paystack operates as an independent data controller for payment data and is subject to its own privacy policy and PCI DSS compliance requirements. We only share the minimum information required to initiate and process transactions, including your name, email address, and payment amount.

You can review Paystack's privacy policy at paystack.com/privacy.

National Pet Database (NPD) Public Search

The NPD includes an optional public search feature designed to help reunite lost pets with their owners. If you enable the "Allow Public Search" setting for your pet's profile, the following information becomes searchable by the public:

• Pet name, type, breed, colour, and photograph
• NPD ID
• Your city and state (not your full address)
• Your first name and contact details (for reunification purposes)

Legal Requirements

We may disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to:

• Comply with a legal obligation or court order under Nigerian law
• Respond to lawful requests from public authorities, including law enforcement or national security agencies
• Protect and defend the rights, property, or safety of Skeepy, our users, or the public
• Investigate potential violations of our terms of service

We take the security of your personal information seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

• SSL/TLS encryption - All data transmitted between your browser and our servers is encrypted using industry-standard SSL/TLS protocols (HTTPS)
• Secure password storage - User passwords are hashed using strong one-way encryption algorithms and are never stored in plain text
• Payment security - All payment processing is handled by Paystack, which maintains PCI DSS Level 1 compliance - the highest level of security certification in the payments industry
• Access controls - Access to personal data is restricted to authorised Skeepy team members who need the information to perform their duties
• Secure hosting - Our website and databases are hosted on secure servers with firewall protection, intrusion detection, and regular security monitoring
• Regular security reviews - We periodically review and update our security practices to address emerging threats and vulnerabilities
• Data backup - Regular encrypted backups ensure data recovery in case of system failures

Under the Nigeria Data Protection Regulation (NDPR) and the Nigeria Data Protection Act 2023 (NDPA), you have the following rights regarding your personal data:

• Right of access - You have the right to request a copy of the personal data we hold about you and your pet(s). We will provide this information in a commonly used electronic format within 30 days of your request.
• Right to rectification - You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most information directly through your Pet Dashboard or NPD profile, or by contacting us.
• Right to erasure (deletion) - You have the right to request that we delete your personal data, subject to certain exceptions (e.g., where we are required to retain data for legal, tax, or regulatory compliance, or where there are outstanding claims or financial obligations).
• Right to data portability - You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another service provider.
• Right to withdraw consent - Where we process your data based on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal.
• Right to object - You have the right to object to the processing of your personal data in certain circumstances, including processing for direct marketing purposes.
• Right to restrict processing - You have the right to request that we restrict the processing of your personal data in certain circumstances, such as while we verify the accuracy of data you have contested.
• Right to lodge a complaint - If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

What Are Cookies

Cookies are small text files placed on your device when you visit a website. They help the website remember your preferences and understand how you use the site.

How We Use Cookies

We use cookies and similar tracking technologies for the following purposes:

• Essential cookies - Required for basic website functionality, such as keeping you logged into your Pet Dashboard or admin panel. These cannot be disabled.
• Session cookies - Maintain your session while you browse our website. These are temporary and are deleted when you close your browser.
• Analytics cookies - Help us understand how visitors use our website, which pages are most popular, and where users experience issues. We use this data to improve our services.
• Functional cookies - Remember your preferences (such as language, region, or display settings) to provide a more personalised experience.

Managing Cookies

Most web browsers allow you to control cookies through their settings. You can typically:

• View what cookies are stored on your device
• Delete individual or all cookies
• Block cookies from specific or all websites
• Set your browser to notify you when a cookie is being placed

Please note that disabling essential cookies may affect the functionality of our website, particularly features like the Pet Dashboard login and form submissions.

Our services are not directed at children under the age of 18. We do not knowingly collect personal information from children under 18. Pet HMO enrolment, NPD registration, and all account creation on Skeepy must be performed by an adult (18 years or older).

If we become aware that we have inadvertently collected personal data from a child under 18 without verifiable parental consent, we will take steps to delete that information as promptly as possible.

If you are a parent or guardian and believe your child has provided us with personal data, please contact us at info@skeepy.co so we can take appropriate action.

Our website may contain links to third-party websites, services, or applications that are not operated by Skeepy. These may include:

• Paystack (payment processing)
• Social media platforms (Instagram, Facebook, X, TikTok, LinkedIn, YouTube)
• Partner clinic websites
• WhatsApp (for customer support)

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We strongly encourage you to review the privacy policy of every site you visit.

The inclusion of a link to a third-party website does not imply endorsement by Skeepy of that website or its content.

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. Our retention periods are as follows:

• Active HMO accounts - Your data is retained for the duration of your active subscription and for a period of 3 years after your last subscription expires or is cancelled, to allow for potential reactivation, dispute resolution, and regulatory compliance
• NPD registrations - Pet profiles on the National Pet Database are retained indefinitely (for the lifetime of the pet) unless you request deletion. This is because the NPD serves as a permanent identification record for pets in Nigeria.
• Payment records - Transaction records are retained for a minimum of 6 years in compliance with Nigerian tax and financial regulations
• Claims records - Records of veterinary claims and treatments are retained for 5 years after the claim is processed
• Skeepy Camera photos, with their time and location - Retained with the payment they belong to, for as long as payment records are kept
• KYC (Identity Verification) details and face photographs - Retained while you have a Skeepy account and for 5 years after it closes, or longer where they are needed for a fraud investigation or legal claim that is under way
• Communication records - Customer support correspondence is retained for 2 years from the date of the last interaction
• Cheerleader and clinic accounts - Data is retained for the duration of the active partnership and for 3 years after termination
• Usage and analytics data - Aggregate analytics data may be retained indefinitely. Individual usage data is anonymised or deleted after 12 months

When the retention period expires and there is no longer a legal or business need to retain your data, we will securely delete or anonymise it.

We may update this Privacy Policy from time to time to reflect changes in our practices, services, legal requirements, or for other operational, legal, or regulatory reasons. When we make changes:

• The "Last Updated" date at the top of this page will be revised
• For significant changes, we will notify you via email (to the email address associated with your account) or through a prominent notice on our website
• Your continued use of our services after changes are posted constitutes acceptance of the revised policy

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. If you disagree with any changes, you may discontinue using our services and request deletion of your data.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please do not hesitate to contact us:

Data Controller

The data controller responsible for your personal information is:

Skeepy Pet Solutions Limited
Lagos, Nigeria
Email: info@skeepy.co

Regulatory Authority

If you are not satisfied with our response to your data protection concerns, you have the right to lodge a complaint with the:

Nigeria Data Protection Commission (NDPC)
Website: ndpc.gov.ng