1. Introduction

Early Detection and Prevention Unit (EDPU) Africa CBC (“EDPU Africa,” “we,” “our,” or “us”) is a Community Benefits Company established in 2021 in Rwanda. Our mission is to foster universal access to the early detection and prevention of Non-Communicable Diseases (NCDs) in Rwanda and across Africa through AI-supported digital screening solutions.

We are committed to protecting your privacy and ensuring that your personal and health information is handled lawfully, fairly, and securely.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our digital clinic platforms, applications, websites, and services (collectively, the “Services”).

2. Information We Collect

a) Personal Information

• Full name
• Date of birth
• Gender
• Contact details (phone number, email address, address)
• National ID or patient identifier (where required by law)

b) Health and Screening Information (Sensitive Data)

• Non-Communicable Disease screening results
• Medical history relevant to NCD risk
• Vital signs and lifestyle-related data
• AI-generated risk assessments and screening insights

c) Technical and Usage Information

• Device type, operating system, and browser
• IP address
• App usage data and timestamps
• Log files and analytics data

3. How We Use Your Information

• Provide, operate, and improve NCD screening and prevention services
• Support early detection and preventive healthcare interventions
• Generate AI-assisted health insights and risk assessments
• Communicate screening results, follow-ups, and health recommendations
• Improve platform performance, security, and user experience
• Comply with legal, regulatory, and public health obligations

We do not sell your personal or health data.

4. Legal Basis for Processing

• Your explicit consent, especially for health data
• Performance of healthcare services requested by you
• Compliance with legal and regulatory obligations
• Public health and preventive healthcare purposes
• Legitimate interests, while respecting your rights and freedoms

5. Use of Artificial Intelligence

EDPU Africa uses Artificial Intelligence to support disease screening and risk assessment. AI tools do not replace medical professionals and are used to support early detection and prevention. Human oversight is maintained in clinical decision-making.

6. Data Sharing and Disclosure

We may share your data only with:

• Licensed healthcare professionals involved in your care
• Trusted technology and cloud service providers under strict confidentiality agreements
• Research partners, only in anonymized or aggregated form
• Government or regulatory authorities, where required by law

We do not share identifiable health data for marketing or advertising purposes.

7. Data Storage and Security

We implement appropriate technical and organizational safeguards, including encryption, access controls, secure servers, and regular system monitoring.

Your data is stored only for as long as necessary to fulfill the purposes described in this policy or as required by law.

8. Your Rights

• Access your personal and health data
• Request correction of inaccurate or incomplete data
• Withdraw consent at any time
• Request deletion or restriction of processing
• Object to certain types of data processing
• Request a copy of your data (data portability)

9. Children’s Privacy

EDPU Africa’s Services are intended for use by individuals in accordance with applicable healthcare laws. Where services involve minors, consent from a parent or legal guardian is required.

10. Cross-Border Data Transfers

Where data is transferred outside Rwanda or your country of residence, we ensure appropriate safeguards are in place in compliance with applicable data protection laws.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be posted on our platforms with a revised “Last Updated” date.