NDPA 2023 Compliant

Privacy Policy

Your privacy matters deeply to us. This policy explains how GHEALEAD collects, uses, and protects your personal information with care and transparency.

Last updated: June 13, 2026

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Privacy Policy

At GHEALEAD Trauma Recovery Limited (hereinafter referred to as GHEALEAD), we respect your privacy and recognize that individuals who visit this platform may be navigating deeply personal and sensitive experiences. Read this Privacy Policy carefully because it discusses how we will collect, use, share, and process your personal information. We are committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information ("Personal Information"). As part of this commitment, our privacy policy governs our actions as they relate to the collection, use, and disclosure of Personal Information. This Privacy Policy is developed in accordance with the Constitution of the Federal Republic of Nigeria, the Nigeria Data Protection Act 2023 (NDPA), and all applicable regulations, guidelines, and directives issued by the Nigeria Data Protection Commission (NDPC). By accessing our Site, you agree to this Privacy Policy and its terms and consent to have your data transferred to and processed in the Federal Republic of Nigeria.

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Cross-Border Data Transfers

Some of our service providers, infrastructure, or technical partners may process personal data outside Nigeria. Where personal data is transferred outside the Federal Republic of Nigeria, such transfers are carried out in accordance with the Nigeria Data Protection Act 2023 and subject to appropriate safeguards to ensure the continued protection of your personal data.

Your use of our Site is also governed by our Terms of Use. Please read those terms carefully as well. We are responsible for maintaining and protecting the Personal Information under our control. We have designated an individual responsible for compliance with our privacy policy. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

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Introduction

GHEALEAD Trauma Recovery Limited is a virtual trauma recovery organization that provides trauma related solutions, through therapy, support groups and resources that facilitate healing, combining Christian and psychological principles.

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Collection and Use of Your Personal Data

We collect, use, and disclose Personal Information to provide you with the counseling, or service you have requested and to offer you additional services we believe you might be interested in. The purposes for which we collect Personal Information will be identified before or at the time we collect the information. In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name and address is provided as part of the order process.

You may browse certain sections of our website without actively providing personally identifiable information. However, we may collect personal data when you voluntarily submit it to us or when information is automatically collected through your use of our Site, such as through log files, or similar technologies, as described in this Privacy Policy.

This information is used by the organization for the operation of the service, to maintain the quality of the service, and to provide general statistics regarding how the organization's website is used.

The Organization encourages you to review the privacy statements of websites to which you choose to link from the Organization so you can understand how those websites collect, use, and share your information. The Organization is not responsible for the privacy statements or other content on websites outside the Organization and affiliate's websites.

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Lawful Basis for Processing Personal Data

We process personal data only where there is a lawful basis to do so under the Nigeria Data Protection Act 2023. Depending on the nature of your interaction with us, this lawful basis may include:

  • Your consent, where you have freely given, specific, informed and unambiguous permission for us to process your personal data;
  • Performance of a contract, where processing is necessary to provide services, products, courses, or functionality you have requested;
  • Compliance with a legal obligation, where processing is required to comply with applicable laws or regulatory requirements; and
  • Legitimate interests, where processing is necessary for the operation, security, improvement, and administration of our services, provided such interests do not override your fundamental rights and freedoms.
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Use of Your Personal Information

The Organization collects and uses your personal information to operate the Organization website and deliver the services you have requested. The Organization also uses your personally identifiable information to inform you of other services available from the Organization.

In the ordinary course of its operations, the Organization does not sell, rent, or lease its customer lists to third parties. Please be advised that the Organization websites will only disclose your personal information without notice if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on the Organization or the site; (b) protect and defend the rights or property of the Organization; or (c) act under exigent circumstances to protect the personal safety of users of the Organization or the public.

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Children Privacy

Our services are not intended for use by individuals under the age of 18 without parental or guardian consent. We do not knowingly collect personal data from children without such consent. If you believe that a child has provided us with personal data without appropriate consent, please contact us so that we may take appropriate steps to delete such information.

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Your Personal Information: How We Collect, Use, and Share It

Below is a brief overview of the personal information collected on our Site and the purpose of our collection. Please note, however, that our processing of your information depends on the information you choose to provide and the functionality of the services you choose to use. A more detailed description of our processing of your information is found below:

How we use your data to make your experience on our Site more personal. This Privacy Policy outlines the types of data we collect from your interaction with Our Site, as well as how we process that information to enhance your experience. When you create an account or access any one of the resources on the sites, the information we collect is for the purpose of offering a more personalized experience.

Your privacy is protected. We take the privacy of the information you provide and that we collect seriously and we implement security safeguards designed to protect your data as discussed below. We do not share your personally identifiable data with any third-party advertisers or ad networks for third-party advertising purposes.

The information we collect depends on the services and functionality you request. You may decline to submit personal information to us; however, that may prohibit us from having the ability to provide you with certain services or functionality. The personal information we collect and the purpose for which we use that information are described below. The Organization makes every effort to secure your personal information from unauthorized access, use, or disclosure. The Organization protects the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Personal Identifiers (name, email address, address, and similar identifiers)

Collected to the extent you provide it to us to create an account or for association with your account in order to ensure proper use and authentication for your account. Your personal information is also used to contact you in connection with your requests and account as discussed in our Privacy Policy.

Geolocation data (physical addresses)

Collected if you choose to use the location-based functionality of our services, however, this information is maintained only on your device and is not stored by us.

Sensitive Information (religious information, national origin, race, marital status, health-related information, genetic information, and similar sensitive data)

Your use of our app or services does not reflect any specific sensitive information, and we do not require that you provide us with the same in order to use our services. We do not require users to disclose detailed trauma histories or highly sensitive personal information in order to access our resources. Where you voluntarily provide sensitive personal data, including information relating to health, trauma experiences, or emotional wellbeing, such data shall be processed strictly with your explicit consent and solely for the purpose for which it was provided. Access to sensitive personal data is restricted to authorised personnel only, subject to heightened confidentiality and security safeguards. We do not require the disclosure of detailed trauma histories or highly sensitive personal information as a condition for accessing general resources on our platform.

Information about our users based on data made available to us

Collected as you use our sites and services as feedback in order to improve and customize your experience about our services and to suggest additional functionality and services.

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Personal Data Retention

We retain personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, including to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. Account information is retained for as long as a user maintains an active account and for a reasonable period thereafter, unless deletion is requested or retention is required by law. Communications and transactional records may be retained for audit, compliance, and operational purposes in accordance with applicable legal requirements.

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Personal Information You Provide to Us

To access services on the Organization's website, we require that you provide a first name, last name, and a valid email address with other necessary payment information required by a third party and in this instance the payment gateway. As a user, you will also be required to fill a Know Your Customer (KYC) form. We will use this information to associate you with your specific account. You may also choose to provide your gender, age, website, description of your location, profile picture, and other information.

Beyond the personal information collected to create an account, you have choices about what additional information you provide to us. We collect personal data from you when you provide, post, or upload it to Ghealead Trauma Recovery Ltd website. You do not have to provide this information; however, if you do not, it may limit our ability to personalize our Site and your ability to use our Site to its fullest extent. Specific Site functionality for which you may provide and we may process your information is discussed below.

As of the date of this Policy, we use Paystack or Flutterwave to process your online payments. For information on how these third parties process your information, please refer to their privacy policies, which may be found here:

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Attribution Providers

The Organization uses third-party websites like Zoom, Flutterwave and Paystack and uses third-party software development kits ("SDKs") on the third-party site. We do not sell your personal information to any third parties nor allow our SDK service providers to sell your personal information to third parties or use your personal information to solicit the sale of third-party goods or services. We may provide these third parties with aggregate, de-identified information concerning ads placed on their sites and downloads that result from those ads.

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Subscribers

We use the personal information you provide to create and maintain your subscribed account. We also use this information to authorize and authenticate your access to your account. We store this information and information pertaining to your use of our Sites in connection with your subscribed account for so long as you are subscribed. For example, your first and last name and email address will be stored and used by us in connection with your account name or auto-generated account ID to authenticate you as the correct user of your account.

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GHEALEAD Trauma Recovery Limited's Content

We collect the manner in which you use Ghealead Trauma Recovery Limited's website and its content, such as your requests, programs and services accessed.

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Communications From You to Us

We collect information about you when you send, receive, or engage with messages from us, including when you submit personal information or requests by emailing hello@ghealead.com. We retain and use those communications to process your inquiries, respond to requests, and improve Our Site and services.

We communicate with you through push notification or email. If we communicate with you by email, you may generally unsubscribe to these messages via the unsubscribe link in the emails providing these messages.

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Recommendations and Other Communications

We use the data we have about you and inferences we make from that data to recommend certain content and functionality as well as additional services offered through the Organization's website. We may contact you through push notifications, and email to notify you of these recommendations and opportunities, how to use our Sites, and other news messages.

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Notice

We may use your personal information to provide notice regarding a security incident or data breach, by: (i) sending a message to the email address you provide (as applicable); (ii) posting to a publicly facing page of Ghealead Trauma Recovery Limited; (iii) through major statewide media; and/or (iv) telephonic means, including calls and/or text messages, even if sent via automated means including automated dialers. Standard text and data messaging rates may apply from your carrier. Notices sent by email will be effective when we send the email, notices we provide by posting will be effective upon posting and by in-app messaging when the message is made, and notices we provide through telephonic means will be effective when transmitted or dialed. You consent to receive electronic communications from us and your use and access to the services provided through our Sites. It is your responsibility to keep your email address and any other contact information you provide to us as current so that we may provide these communications to you.

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Analytics and Performance

We internally analyze the personal data available to us and the use of our content, as well as the inferences we make from that data, to provide and update our sites, communicate with you, and process information as discussed in this Policy, and for internal analytics such as to observe social, economic, and geographic trends as they pertain to our content. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy, as discussed below. We may disclose the use of our sites' content in an aggregated manner with de-identified and anonymized information that does not disclose any particular user or that user's personally-identifying information. For example, we may use your data to generate statistics about the overall usage of websites worldwide in specific geographic regions or at specific events or locations.

We also use de-identified and aggregate user data to market our websites, including communications that promote our network growth, such as celebrating the total number of website visits, enrollment in courses and seminars and number of subscribers worldwide. When you see statistics we share publicly such as global reach and engagement, we make sure to analyze and publish the data in an aggregated form, protecting your privacy and keeping your identity and personal information confidential.

We use data, including user provided personal information, aggregations of user data, data collected through the use of our sites, public feedback, and information inferred from this data to conduct internal research and development in order to provide a better overall websites experience, measure the performance of our sites, and increase the use of Ghealead Trauma Recovery Limited's website and its features. This is done by making changes to our sites that are generally available.

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Sensitive Data

We will not sell your sensitive personal information, but we may need to share it with third-party service providers that enable us to provide certain features, and those service providers are required to keep your personal information confidential and only use it to provide us with their services. We will process the sensitive information we collect and inferences we make about the same in accordance with our Privacy Policy and for the purpose of allowing and facilitating your use of those specific app features, to personalize your user experience, to suggest other content and services, and internally to improve our services. If you choose to provide any sensitive information to us, we may use that information with other non-sensitive information you provide to create a more personalized experience for you and to perform the services and actions you request, such as sharing or storing content you create. In any event, we will only process sensitive data you provide to us for our legitimate activities on your behalf and solely in accordance with the terms of this policy and any additional requests you make about the information. We will also maintain your information subject to appropriate safeguards discussed in this policy and otherwise provided by us.

You have the right to withdraw your consent to our collection and processing of your sensitive personal information by ceasing to use our Features that use this information or by contacting us via mail at Ghealead Trauma Recovery Limited Support, Attn.: Ghealead Trauma Recovery Limited Support, email at: support@ghealead.com. However, withdrawing your consent may hinder our ability to provide certain functionality.

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Disclosure of Your Information

We do not sell or share your personal data with any third-party advertisers or ad networks for their advertising purposes. We may disclose your personal information to third parties in order to process information as described above and otherwise enable our ability to provide our Services, as further discussed below.

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Disclosure on Your Behalf

We may disclose personal information that we collect or you provide as described in this Privacy Policy to fulfill our obligations under our Terms of Use, to accomplish the purpose for which you provide it, for any other purpose you request when you provide the information, or for any other purpose for which we have your consent.

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Disclosure by You

When you share information through our sites, that information is viewable by you and by anyone else you choose to share it with. If you give access to your information to other applications and services, based on your approval, those services would then have access to your shared information. The use, collection, and protection of your data by such third-party services is subject to those third parties' policies.

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Internal Disclosure

We will process your personal data internally within the organization and its affiliates to help combine the personal information covered across the different aspects of our services to help provide services to you in a manner that is personalized and useful to you and others.

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Disclaimer

The information provided on the organization's website is intended for general educational and informational purposes only. While the platform offers trauma recovery resources, reflective tools, and supportive content, it does not provide medical, psychological, psychiatric, or emergency services. Nothing on this website should be interpreted as professional advice, diagnosis, treatment, or a substitute for consultation with qualified health or mental health professionals.

Use of this website does not create a doctor–patient or any other professional relationship. Any actions you take based on information obtained from this platform are taken at your own discretion and responsibility.

The content on this website is designed to support personal insight, learning, and self-reflection. Trauma experiences are complex and individual, and outcomes may vary significantly from person to person. Ghealead Trauma Recovery Limited makes no guarantees regarding emotional healing, recovery timelines, or specific results from the use of its content or services.

If you are experiencing acute distress, suicidal thoughts, self-harm ideation, or are in immediate danger, you should seek urgent help from emergency services, crisis hotlines, or qualified professionals in your local area. This platform is not equipped to respond to emergencies or crisis situations.

While we strive to ensure that the information provided on this website is accurate, current, and responsibly presented, the organization makes no representations or warranties of any kind regarding the completeness, accuracy, reliability, or suitability of the content. We are not responsible for errors, omissions, or outcomes arising from the use of information on this platform.

Any third-party links, resources, or references provided are for convenience and informational purposes only. The organization does not endorse, control, or assume responsibility for the content, policies, or practices of third-party websites or services.

To the fullest extent permitted by law, the organization, its directors, affiliates, contributors, shall not be liable for any direct, indirect, incidental, consequential, or emotional damages arising from the use of, or inability to use, this website or its content.

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Service Providers and Locations

We may disclose personal information that we collect or you provide as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our Sites (such as cloud hosting, maintenance, analysis, audit, external marketing, payment, fraud detection, and development), as well as to support our operations (such as communicating with you for potential employment purposes). We may combine information we have with information of these service providers to facilitate their support. For example, some of the platforms used to send emails and notifications provided through our sites are built and managed by third parties, so some of your information is sent securely to those services to provide such functionality. They will have access to your information only as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. We may also provide aggregate, de-identified information concerning connections by our users with third-parties and their events or locations.

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Deleting, Accessing, and Correcting Your Information

For personal data that we have about you, you may request the following:

We ask that individuals making requests identify themselves with at least their name, address, and email address and identify the information requested to be accessed, corrected, or removed before we process any request. We may seek additional information to verify a requestor's identity. We may also decline to process requests if we cannot verify the requestor's identity or if we believe the request will jeopardize the privacy of others, violate any law or legal requirement, would cause the information to be incorrect, or for a similar legitimate purpose.

We will not discriminate against you for exercising any of your rights under applicable law. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Some information you have created, received, or used in our sites may not be available in a usable form outside of our sites. As a result, when you request a copy of your personal information, we will be able to provide personal information you have provided to us, such as your name, address, phone number and the likes; however, we may be unable to provide any other information outside that scope.

  • Deletion: You may ask us to erase or delete all or some of your personal data. Please note that doing so may limit your ability to use certain functionality of our sites. Please note that an email address is required to ensure we can properly authenticate potential users of that account.
  • Correction/Modification: You may edit some of your personal data through your account or ask us to change, update, or fix your data in certain cases, including if it is inaccurate.
  • Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data or to limit our use of it.
  • Right to Access and/or Take Your Data: You can ask us for a copy of or disclosure concerning your personal data you provided to us.
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Security and Protection

We implement security safeguards designed to protect your data. These include using encryption for your data while it is being transmitted between your device or browser and our servers and while it is at rest. Data provided to us through our sites is also stored in an ISO 27017-certified infrastructure management system, meaning it has been audited and found in compliance with the requirements of the management system standards ISO 27017, which ISO are we using an internationally recognized code of practice for information security controls for cloud services.

We store personal data using reputable cloud-based infrastructure providers that implement internationally recognised information security standards and controls designed to protect personal data.

However, given the nature of communications and information technology, and that the use of the internet has inherent risks, although we regularly monitor for possible vulnerabilities and attacks, we cannot warrant or guarantee that information provided to us through the organization's website or stored in our systems or otherwise will be absolutely free from unauthorized intrusion by others, nor can we warrant or guarantee that such data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

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Changes to Our Statement of Privacy Policy

We may occasionally update this Statement of Privacy policy to reflect changes in practice. The Organization encourages you to periodically review this statement to be informed of how the Organization is protecting your right to privacy and your information. We are consistently seeking new and improved ways to offer bespoke services and increase engagement. As we improve on our sites, this may mean the collection of new data or new ways to use data. Because we are dynamic, and we continuously seek to offer new features, we may require changes in our collection or processing of information. If we collect materially different personal data or materially change how we use your data, we will update this Privacy Policy. We will post any changes to our Privacy Policy on this page. If we make material changes to how we process our users' personal information, we will provide a notice that the Privacy Policy has been updated. The date the Privacy Policy was last modified will be identified at the beginning of the Policy and our archived versions will also be attached. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Policy to check for any changes.

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Contact Information

By accessing and using this website, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

We have designated a data protection contact responsible for overseeing compliance with this Privacy Policy and applicable data protection laws.

Data Protection Contact / Privacy Officer: legal@ghealead.com

Questions about your privacy?

Reach out to our Data Protection Contact for any privacy-related requests or concerns.

legal@ghealead.com

See also our Terms of Use · support@ghealead.com