Legal

Privacy Policy

Version 1.1 (Beta)

Effective Date: October 8, 2026. Last Updated: October 14, 2026.

The short version

• Toju helps you organise health records. It does not give medical advice or diagnose.
• We ask the person whose information it is to agree, by email link. They can withdraw at any time, and withdrawing deletes their records.
• AI helps read the documents you upload. A person confirms what it found before it is saved.
• Documents are stored privately. Only the account that uploaded them can see them.
• We do not sell your information, and we do not use it for advertising.
• Our service providers process information for us. Your information is stored in the United States.
• To see, correct or delete your information, email abolaji@toju.health.

This summary is a convenience. The full policy below is what applies.

PART I — Understanding Toju

About this Privacy Policy

This Privacy Policy explains how Toju Health ("Toju," "we," "us," or "our") collects, uses, stores, discloses, and otherwise processes personal information through the Toju Health platform and related services.

Toju is a health information coordination platform designed to help individuals organise and coordinate health information for themselves and, where properly authorised, for family members. Toju is a coordination and information-management service. It does not provide medical advice, diagnose conditions, interpret medical results, recommend treatment, or replace the judgment of a qualified healthcare professional.

Because the information handled through Toju may include sensitive health information, we apply additional safeguards to its collection, use, access, and disclosure.

Purpose of This Policy

This Privacy Policy is intended to help you understand:

1. what personal information we collect and how we collect it;
2. how we use and protect personal and health information;
3. how documents and other health information may be processed using optical character recognition (OCR) and artificial intelligence (AI);
4. when and why information may be shared with service providers and other parties;
5. how information may be stored or processed across jurisdictions;
6. how long we retain information and how it may be deleted;
7. the rights and choices available to you; and
8. how you can contact us or raise a privacy concern.

This Policy should be read together with any other notices or terms we provide when you use particular Toju features or services.

Who This Policy Applies To

This Policy applies to individuals who use Toju as:

1. Profile Owners: individuals whose health information is maintained in a Toju profile. A Profile Owner may use Toju for their own information. Where another person sets up a profile for them, the Profile Owner is asked to agree by an emailed link, and can withdraw that agreement at any time without needing a Toju account.
2. Coordinators: individuals who create a Toju account and use it to help manage another person's health information, after that person has been invited to agree.
3. Website visitors and waitlist members: individuals who visit toju.health or give us their email address to hear about the beta or launch.

Note:

• An individual may be both a Profile Owner and a Coordinator.
• Each profile is currently managed from a single Toju account. Sharing one profile between several accounts is not yet available.
• Being a family member, caregiver, or other person connected to a Profile Owner does not, by itself, give that person access to the Profile Owner's information. Agreement is required before a Coordinator can manage another person's health information through Toju.
• Where a Coordinator uploads information relating to another person, the fact that the Coordinator uploaded the information does not, by itself, make the Coordinator the Profile Owner or give the Coordinator unrestricted rights over that information.

Services Covered by This Policy

• This Policy applies to personal information processed through Toju's websites, applications, platform features, and related services that link to or expressly adopt this Policy.
• Toju may also provide support, communications, account-management functions, and other services connected with the platform. This Policy applies to the personal information processed through those services to the extent described here.
• Third-party websites, applications, or services that are not operated by Toju may have their own privacy policies. Where Toju uses a third party to process information on its behalf, that processing is addressed under the sections of this Policy concerning service providers and information sharing.

Our Approach to Privacy

Toju is designed around the principle that individuals should have meaningful control over their health information.

Where Toju processes information about a Profile Owner, the Profile Owner remains the person whose information is being managed, even where another person coordinates that information on their behalf. Toju's approach is therefore based on the Profile Owner's agreement rather than family relationship alone.

Subject to the applicable law and the functionality of the service:

• individuals can manage information relating to themselves;
• a Profile Owner is asked to agree before a Coordinator manages their health information, and can withdraw that agreement at any time;
• when a Profile Owner withdraws their agreement, we delete their health records and health details, as described under Retention & Deletion;
• we seek to limit the collection, use, disclosure, and retention of information to what is reasonably necessary for the purposes described in this Policy;
• AI-assisted processing is subject to human review before information extracted from documents is added to a health timeline; and
• we do not sell personal health information, and we do not use it for advertising.

Applicable Privacy Requirements

Toju Health is based in Canada and is designed to support individuals in Canada who may coordinate health information relating to family members in Nigeria and other jurisdictions. Our privacy practices are intended to address applicable privacy and data protection requirements, including the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada and the Nigeria Data Protection Act, 2023 (NDPA) where applicable. Other federal, provincial, territorial, or foreign privacy laws may also apply depending on the individual, the information involved, the location of the person concerned, and the nature of Toju's activities.

For example, provincial health privacy legislation may apply in particular circumstances depending on Toju's activities and relationships with healthcare organisations. Nothing in this Policy is intended to limit any privacy rights or protections that apply to you under applicable law.

Effective Date and Changes to This Policy

Effective Date: October 8, 2026. Last Updated: October 14, 2026. Version: 1.1 (Beta).

We may update this Privacy Policy from time to time to reflect changes to our services, information practices, technology, legal requirements, or other circumstances.

When we make material changes, we will take reasonable steps to notify affected users, including by posting an updated Policy through the Toju platform or website and, where appropriate, providing additional notice. The updated Policy will identify its effective date.

Your continued use of Toju after the effective date of an updated Policy will be subject to the revised Policy, except where applicable law requires a different form of notice or consent.

PART II — What Happens to Your Information

Information We Collect

The information we collect depends on how you use Toju, whether you manage your own health information or coordinate information for another person, and which features you use.

Account and Identity Information

When you create or use a Toju account, we may collect information such as:

1. name and contact information, including email address;
2. account credentials and authentication information;
3. account and profile identifiers;
4. the version of our terms and consent notices you accepted, and when; and
5. information needed to manage your account, permissions, and access.

Health Information

Toju may process health information that you or an authorised person choose to add to a profile. This may include:

1. prescriptions and medication information;
2. laboratory and diagnostic results;
3. medical notes, reports, and other clinical documents;
4. diagnoses or health conditions contained in those documents;
5. healthcare provider information;
6. dates associated with healthcare events or documents;
7. profile details you enter, such as date of birth, gender, blood group, blood pressure, heart rate, weight, height, allergies, chronic or self-reported conditions, and a general location; and
8. other health information that you choose to organise through the platform.

Health information is sensitive personal information. We therefore apply additional safeguards to its handling as described in this Policy.

Information Extracted From Health Documents

When you upload a document or image, Toju may use automated technologies to identify and structure relevant information contained in that material. This may result in information such as medication names, diagnoses, dates, healthcare providers, or other fields being extracted from the document.

Extracted information is not treated as confirmed solely because an automated system identified it. Toju requires a person to review and confirm or correct the information before adding it to the health timeline.

Invitation, Consent and Withdrawal Information

Where a Coordinator sets up a profile for another person, we collect and keep:

• the name of the Coordinator and the name and email address of the person invited;
• whether the invitation is pending, accepted, declined, or withdrawn;
• the time the person responded, and the version of the consent notice they were shown;
• the IP address and browser or device information of the device they used to respond; and
• the time and IP address of any withdrawal.

We also keep an audit log of consent events, so that we can show when and how agreement was given or withdrawn.

Waitlist and Website Information

If you join the waitlist, we collect your email address, the time you signed up, and your answers to four short questions: where you live, who you help care for, where they live, and how you heard about Toju. We use these answers only to plan the beta and to understand which of our outreach reaches people. Our hosting providers may also log technical information, such as IP address and browser type, when you visit toju.health.

Usage and Technical Information

When you use Toju, we may collect information necessary to operate, secure, maintain, and improve the service. Depending on the features implemented, this may include device, browser, log, account activity, diagnostic, and usage information.

We will describe material changes to the types of usage or analytics information collected through this Policy or appropriate notice.

Information You Provide About Others

You may provide information about another person where you are authorised to coordinate their health information, including the name and email address of the person you invite. You should only provide another person's information where you have the authority or permission to do so.

Providing information about another person does not, by itself, determine that person's rights or permissions under applicable privacy law. Toju will process the information according to the applicable authorisation and legal requirements.

How We Collect Information

We collect information through several sources, depending on how you interact with Toju.

1. Directly From You - We collect information you provide when you:
   • create or manage an account;
   • create or update a profile;
   • upload health documents, photographs, or other information;
   • enter or correct health information;
   • invite another person or respond to an invitation;
   • join the waitlist;
   • communicate with us; or
   • otherwise use features that require you to provide information.
2. From Coordinators - A Coordinator may provide information relating to a Profile Owner after inviting that person to agree. The Profile Owner may also confirm information directly, or withdraw their agreement.
3. From Uploaded Documents - When a document or image is uploaded, Toju may process the content of that material to identify and structure relevant information. This involves OCR and other automated processing technologies used by Toju or its service providers.
4. Automatically Through Use of the Platform - We may collect certain technical and usage information automatically when you access or use Toju, including information relating to your device, browser, interactions with the platform, and system activity.
5. From Service Providers - Certain information may be generated or processed through service providers that support Toju's infrastructure, security, document processing, authentication, or other platform functions. These providers may process information only for purposes authorised by Toju and subject to applicable contractual and legal requirements.

How We Use Information

Toju uses personal information for purposes connected with providing, securing, administering, and improving the platform. This includes:

1. Providing the Toju Service - We use information to:
   • create and maintain accounts and profiles;
   • store and organise health information;
   • create and maintain health timelines;
   • send invitations and record agreement and withdrawal;
   • allow users to review, confirm, correct, and update information; and
   • provide customer and technical support.
2. Processing Health Documents - We process uploaded documents and the information contained in them to identify, structure, organise, and display relevant health information within the platform. Where automated technologies are used, their purpose is to assist with information organisation. Toju does not use these technologies to diagnose a condition, determine treatment, or replace professional medical judgment.
3. Security and Account Administration - We may use information to:
   • authenticate users and protect accounts;
   • detect, prevent, and investigate unauthorised access or misuse;
   • maintain the security and reliability of the platform;
   • troubleshoot technical problems; and
   • enforce our terms and other applicable policies.
4. Communications - We may use contact information to send service-related communications, including account notices, security alerts, invitations, important changes to the service, and other communications necessary to administer your account. We use waitlist email addresses only to tell you about beta access and launch. Where required by law, we will obtain appropriate consent before sending promotional or marketing communications, and every such email will explain how to unsubscribe.
5. Improving Toju - We may use general usage information, such as how many documents are uploaded or which features are used, to maintain, test, troubleshoot, and improve the platform. We do not use the content of health documents or health records to improve or develop Toju, to train AI models, for advertising, or for profiling.
6. Legal and Regulatory Purposes - We may use or disclose information where reasonably necessary to:
   • comply with applicable law or a lawful request;
   • respond to legal proceedings or enforceable governmental requests;
   • protect the rights, property, or security of Toju, its users, or others;
   • investigate suspected fraud, abuse, or security incidents; or
   • establish, exercise, or defend legal claims.
7. Principles Limiting Our Use of Information - Toju seeks to collect and use information only for identified and legitimate purposes and to limit processing to what is reasonably necessary for those purposes. We do not use Toju to make medical decisions about users. Information available through a Toju profile is intended to help people organise and coordinate information, not to provide medical advice or determine what healthcare a person should receive.

Health Information

Toju is designed to help individuals organise and coordinate health information. Because health information is sensitive, we treat it with a higher level of care and apply safeguards appropriate to the nature of the information.

Whose Health Information Is Being Processed

Health information may relate to:

• you, where you manage your own health information;
• another person, where you have invited them and are coordinating their information; or
• both, where you use Toju for yourself and as a Coordinator for another person.

Where a Coordinator uploads information about a Profile Owner, Toju processes that information for the coordination relationship the Profile Owner has been invited to agree to. The Coordinator's ability to upload information does not give them unrestricted rights to the Profile Owner's information.

No Medical Advice or Decision-Making

Toju is an information coordination service. We do not diagnose medical conditions, interpret medical results for clinical purposes, recommend medication or treatment, or make healthcare decisions.

Information displayed in a Toju profile or timeline should not be treated as a substitute for advice, diagnosis, or treatment from a qualified healthcare professional. Users remain responsible for seeking appropriate professional medical care. Toju is not for emergencies.

Accuracy and User Review

Information entered by users or extracted from documents may contain errors, omissions, outdated information, or inaccuracies. Users are responsible for reviewing information before relying on it for coordination purposes.

Where Toju extracts information from an uploaded document using automated processing, the extracted information must be reviewed and confirmed or corrected before it is added to the health timeline.

Consent and Agreement

Toju's approach is based on the principle that a person should control who manages their health information. A family relationship, caregiving role, or other personal connection does not automatically provide access.

Providing Your Own Information

When you provide your own personal or health information to Toju, you acknowledge that the information will be processed for the purposes described in this Policy and, where required by applicable law, we will obtain your consent or rely on another lawful basis for processing.

You may choose not to provide certain information. However, doing so may prevent you from using features that require that information.

When a Coordinator Sets Up a Profile for Another Person

We send the person an email invitation. The invitation says who invited them, what will be stored and where, and asks them to accept or decline. We record their response, the time, the version of the consent notice they were shown, and the IP address and device information of the device they used.

Withdrawing Agreement

Each accepted invitation comes with a withdrawal link that does not expire and does not need a Toju account. Using it, the Profile Owner can withdraw their agreement at any time. When they do, we delete the health records in that profile, clear the health details held in it, and delete the uploaded documents. We keep only a minimal record that the profile existed and was withdrawn, as described under Retention & Deletion. Anyone who holds the withdrawal link can use it, so Profile Owners should keep it private.

Withdrawal does not undo anything a Coordinator did before it, and it does not affect information the Coordinator has already exported or copied outside Toju.

Coordinator Responsibilities

If you set up a profile for another person, you are responsible for using the access only for the purposes for which it was agreed.

You must not:

• access information without authorisation;
• use another person's information for an unrelated purpose;
• share information with people who have not been authorised; or
• continue using a profile after you know that the Profile Owner has withdrawn their agreement.

Consent Does Not Replace Legal Authority

Where you provide information about another person, you are responsible for ensuring that you have the authority or permission required to do so.

Toju may request additional information or take other reasonable steps where there is uncertainty about a person's authority to provide information or give agreement.

Consent and authorisation requirements may differ depending on the applicable privacy law and the circumstances in which information is collected or used. Toju will apply the requirements applicable to the relevant processing activity.

AI-Assisted Processing

Toju uses automated technologies, including artificial intelligence, to assist with the organisation of information contained in uploaded health documents. These technologies are used to support information management and are not intended to provide medical advice or make healthcare decisions.

How the Process Works

When you upload a photograph, PDF, or other health document:

1. Document storage: The uploaded document is stored in a private storage area within Toju's systems so that it can be processed and made available to the account that uploaded it.
2. Text extraction: The document is read by Tesseract, an open-source OCR tool that runs inside Toju's own systems, to identify and extract the text it contains. The document is not sent to another company for this step.
3. Information structuring: Where Toju's own reading of a document needs help, the extracted text, not the original image, may be sent to our AI provider, OpenAI, which organises it into structured fields, such as medication, diagnosis, date, or healthcare provider. The text may include personal details that appear in the document, such as names, dates, and provider details.
4. Human review: The resulting information is presented for user review. It must be confirmed or corrected before it is added to the user's health timeline as structured information.

The providers used for these functions are named under Service Providers, and may change. We will update this Policy before we start using a different provider for these functions.

What AI Does Not Do

Toju's AI-assisted features are intended to organise information that already appears in a user's documents. They are not designed to:

1. diagnose a medical condition;
2. determine whether a diagnosis is correct;
3. recommend or prescribe treatment;
4. determine whether medication should be started, stopped, or changed;
5. provide medical advice; or
6. make healthcare decisions on behalf of a user.

Accuracy and Human Review

Automated systems can misread, omit, or incorrectly structure information. For that reason, information generated through automated processing is not treated as confirmed medical information solely because an AI system produced it.

Users should review extracted information against the original document and correct any errors before relying on it for coordination purposes. Toju does not represent that automated extraction will always be complete or accurate.

Use of Third-Party AI and Processing Services

Toju uses third-party technology providers to perform AI-assisted structuring, hosting, storage, security, and related functions. These providers process information on Toju's behalf and are subject to contractual, technical, and organisational safeguards appropriate to the services they provide.

No Training Use of User Health Information

We do not use users' health information to train AI models. Under our agreement with OpenAI, the text we send is not used to train its models. OpenAI may keep that text for a limited period for security and abuse monitoring, and our healthcare agreement with OpenAI restricts how it may use or share it. We send text only, never the original document image.

We will update this Policy if our AI processing arrangements change in a way that affects these statements.

AI Processing Does Not Change Your Rights

The use of automated processing does not remove or reduce any privacy rights you have under applicable law. You may contact Toju regarding questions about how your information is processed, including through automated technologies, subject to applicable legal requirements and the limitations of the service.

PART III — Who Can Access It

Sharing Information

Toju does not sell personal information or personal health information, and does not share it for advertising. We disclose information only where reasonably necessary to provide the service, protect users and the platform, comply with legal obligations, or for another purpose permitted or required by applicable law.

We share information:

1. With the Coordinator: A Profile Owner's information is visible to the Coordinator account that manages the profile. Each profile is currently managed from a single account.
2. At Your Direction: If Toju offers a feature that lets you export a summary or share it with a healthcare provider, it goes only where you send it. The recipient's own privacy practices apply to what they receive, and Toju cannot take it back once it has been sent.
3. With Service Providers: We may disclose information to third-party providers that perform services on our behalf, such as hosting, storage, authentication, document processing, security, and technical infrastructure. These providers are addressed in the next section.
4. Where Required or Permitted by Law: We may disclose information where reasonably necessary to comply with a legal obligation, court order, regulatory requirement, or lawful governmental request, or where otherwise permitted by applicable law.
5. To Protect Rights and Security: We may disclose information where reasonably necessary to detect, prevent, or investigate fraud, security incidents, misuse of the service, or activities that may threaten Toju, its users, or others.
6. Business Transactions: If Toju is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable privacy requirements and appropriate safeguards.

Where required, we will provide notice or obtain consent before using or disclosing information for a new purpose that is materially different from the purposes described in this Policy.

Service Providers

Toju relies on selected third-party service providers to operate and maintain the platform. These providers may process personal information on Toju's behalf and only for functions relevant to the services they provide.

Today, the providers are:

The provider list may change as Toju develops. We will maintain appropriate contractual and technical safeguards, and we will update this Policy before we start using a different provider to process health information.

Service providers are not authorised to use Toju information for their own purposes, other than as their terms and applicable law require.

International Transfers

Toju is based in Canada, but personal information may be accessed, stored, or processed in countries other than the country where you live.

Today, Toju's database and file storage are located in the United States. Information about a Profile Owner in Canada, Nigeria, or elsewhere is therefore stored in the United States. Text extraction runs inside Toju's own systems. Our AI provider, OpenAI, may process text in the United States or in other countries, and our invitation email provider, Resend, may process invitation details there too.

By using Toju, and by accepting an invitation, you acknowledge that information will be stored and processed outside your country as described here.

Cross-Border Safeguards

Where personal information is transferred or made accessible across borders, Toju will take reasonable steps to use appropriate contractual, technical, and organisational safeguards and to meet applicable legal requirements governing international transfers.

These measures may include contractual privacy obligations for service providers, access controls, encryption and other security measures, and restrictions on how providers may use the information.

Different Legal Protections

Privacy laws differ between jurisdictions. Information transferred outside your country may be subject to the laws of the jurisdiction where it is processed and may be accessible to courts, regulators, or law enforcement authorities in accordance with those laws.

Toju remains responsible for managing information in accordance with applicable legal requirements and the commitments described in this Policy.

If This Changes

If we move storage or processing to another country, we will update this Policy and give notice as described under Changes to This Policy.

PART IV — How We Protect and Manage It

Retention & Deletion

Toju retains personal information only for as long as reasonably necessary for the purposes for which it was collected, to provide and maintain the service, and to meet applicable legal, regulatory, security, and recordkeeping requirements.

How Long We Keep Information

Health documents and structured health information are kept for as long as the relevant profile or account remains active, unless the information is deleted earlier or a longer retention period is required or permitted by law.

Toju will periodically assess whether personal information continues to be necessary. Information that is no longer required will be securely deleted, anonymised, or otherwise disposed of in accordance with our retention practices and applicable law.

Deleting Your Information

Deleting records and documents. A Coordinator can delete individual records and uploaded documents in the app, where the app offers that option.

When a Profile Owner withdraws their agreement. We delete the health records in the profile, clear the health details held in it (date of birth, gender, blood group, blood pressure, heart rate, weight, height, allergies, conditions, and location), and delete the uploaded documents. This happens straight away. We keep only a minimal record: the name on the profile, the name and email address of the person invited, the dates of the invitation, response and withdrawal, the consent notice version, the IP address used, and an audit log entry. We keep this record for 2 years so that we can show that agreement was given and withdrawn, and then delete it, unless the law requires us to keep it longer.

Other requests. To have your account, profiles, or waitlist email deleted, email abolaji@toju.health. We will complete the deletion within 30 days, except where we must keep information as described below. Closing an account is done by emailing us.

Backups. Copies held in backups are overwritten on our provider's normal backup cycle, within 30 days.

If a Profile Owner has died or cannot manage their own information. A legally authorised representative, such as an executor or substitute decision-maker, may contact us with proof of their authority to withdraw agreement and request deletion. We will not give anyone access to a profile beyond the access the Coordinator already has.

We may also keep information where required or permitted by law, or where reasonably necessary to establish, exercise, or defend legal claims, investigate security incidents, or prevent fraud. Where information is kept for one of these purposes, we will limit its use to that purpose.

Security

Toju takes reasonable technical, administrative, and organisational measures designed to protect personal information against unauthorised access, collection, use, disclosure, alteration, loss, destruction, or other misuse.

The safeguards applied include:

1. sign-in authentication;
2. access rules in the database, so each account can reach only the profiles and records it owns;
3. private file storage, with documents readable only by the account that uploaded them;
4. encryption of information in transit, and encryption of stored data at rest by our hosting provider;
5. an audit log of consent events;
6. safeguards governing access by service providers;
7. procedures for managing security vulnerabilities and incidents; and
8. confidentiality and security requirements for anyone who works with Toju.

No method of transmitting or storing information is completely secure. Accordingly, while Toju works to protect information using reasonable safeguards, we cannot guarantee absolute security.

Users are also responsible for protecting their account credentials and withdrawal links, using appropriate device security, and notifying Toju promptly if they believe their account or information has been accessed without authorisation.

Privacy Incidents

A privacy incident may include unauthorised access to, use, disclosure, loss, alteration, or destruction of personal information.

Toju maintains procedures for identifying, assessing, containing, investigating, documenting, and responding to suspected or confirmed privacy and security incidents.

Where an incident occurs, Toju will assess:

1. what information was involved;
2. whose information may have been affected;
3. the nature and extent of the incident;
4. the likelihood and severity of potential harm;
5. whether the information was accessed, used, disclosed, lost, or otherwise compromised; and
6. what steps are necessary to contain and remediate the incident.

Where an incident creates a real risk of significant harm, we will notify the affected individuals and the Office of the Privacy Commissioner of Canada as PIPEDA requires. Where the NDPA applies and requires it, we will notify the Nigeria Data Protection Commission within 72 hours of becoming aware of the incident. We keep a record of every incident for at least 24 months.

Toju may also take other reasonable measures to reduce the risk of harm, including securing affected systems, restricting access, resetting credentials, investigating the cause, and implementing measures to prevent recurrence.

Cookies and Analytics

Today, toju.health does not use analytics or advertising cookies. The Toju app uses essential cookies or similar browser storage to keep you signed in. The website loads its typefaces from Google Fonts, which means Google receives a visitor's IP address when a page loads.

If we add analytics tools, we will update this Policy first. Toju will not intentionally use analytics tools to collect health information for unrelated advertising or profiling purposes. Where applicable law requires consent for non-essential cookies or similar technologies, Toju will provide an appropriate consent mechanism before using them.

You may be able to block or delete cookies through your browser settings. Blocking essential cookies may stop you from signing in.

PART V — Your Rights and Our Accountability

Privacy Rights

Toju respects the privacy rights available to individuals under the laws applicable to its processing of personal information. Depending on the jurisdiction and circumstances of the processing, these rights may include:

1. Access: the right to request access to personal information held by Toju about you and, where required by law, information about how it was collected, used, or disclosed.
2. Correction: the right to request correction of personal information that is inaccurate, incomplete, or out of date.
3. Deletion: the right to request deletion or destruction of personal information where applicable law provides that right.
4. Consent: the right to withdraw consent where consent is the legal basis for processing, subject to applicable legal exceptions and any processing that Toju is otherwise permitted or required to undertake.
5. Restriction or objection: the right to restrict or object to certain processing where provided by applicable law.
6. Portability: the right to receive or request transfer of personal information where applicable law provides a portability right.
7. Automated processing: rights relating to decisions based solely on automated processing, where provided by applicable law.
8. Complaint: the right to raise a privacy concern with Toju and, where applicable, with the relevant privacy regulator.

These rights are subject to the exceptions, limitations, and conditions established by applicable law. Toju may refuse or limit a request where permitted or required by law, including where responding could affect another person's privacy, interfere with legal obligations, or require disclosure of information that cannot lawfully be provided.

Where a request concerns another person's profile or health information, Toju will require appropriate authorisation or legal authority before providing access. Being a family member, caregiver, or Coordinator does not, by itself, confer a right to access another person's information.

Toju may take reasonable steps to verify identity and authority before responding to a request. Requests will be handled within the timeframes and in accordance with the procedures required by applicable law.

Canada-Specific Information

Applicable Canadian Privacy Laws

Toju is based in Ontario and processes personal information in the course of providing its services. Canadian federal, provincial, or territorial privacy legislation applies to Toju's processing where the relevant statutory requirements are met.

The Personal Information Protection and Electronic Documents Act (PIPEDA) applies to Toju's activities to the extent that its requirements govern the relevant processing.

Provincial or territorial privacy legislation may also apply where it governs the relevant activity. In Ontario, the Personal Health Information Protection Act, 2004 (PHIPA) applies where its statutory requirements are engaged. The fact that Toju processes health information does not, by itself, establish that PHIPA applies to every Toju activity.

Toju will assess and comply with the privacy requirements applicable to the particular processing activity and relationship.

Rights Under Canadian Privacy Law

Where PIPEDA applies, individuals have the rights provided under PIPEDA, subject to its statutory exceptions and limitations. These include the right to:

1. request access to personal information held by Toju about them;
2. obtain information about the existence, use, and disclosure of their personal information where required;
3. challenge the accuracy or completeness of personal information and request appropriate correction; and
4. raise concerns about Toju's handling of personal information.

Where another Canadian privacy law applies, individuals have the rights provided under that law, including any applicable rights relating to consent, correction, deletion, restriction, portability, or objection.

Where PHIPA applies to Toju's activities, individuals have the rights provided under PHIPA, subject to its statutory requirements and exceptions. These include statutory rights relating to access to and correction of personal health information in circumstances covered by the legislation.

Toju will not treat a right as applicable where the relevant statutory conditions have not been met, and will explain any applicable limitation or refusal where required by law.

Exercising Canadian Privacy Rights

Canadian privacy requests may be submitted using the contact information section. Toju may request reasonable information to verify the requester's identity and, where the request concerns another person, the requester's legal authority or authorisation to act on that person's behalf.

Toju will process requests in accordance with the legislation governing the request, including applicable response periods, extensions, exemptions, and procedural requirements.

If you are not satisfied with Toju's response, you may contact the privacy regulator with jurisdiction over the matter. Where PIPEDA applies, this includes the Office of the Privacy Commissioner of Canada. Where provincial or territorial legislation applies, the applicable provincial or territorial privacy oversight body may have jurisdiction.

Nothing in this Policy limits an individual's right to contact a privacy regulator directly where that right is provided by law.

Nigeria-Specific Information

Applicability of Nigerian Privacy Law

Toju may process personal data relating to individuals in Nigeria, including where an individual whose health information is being coordinated is located in Nigeria, and the Coordinator is located outside Nigeria.

Where the Nigeria Data Protection Act, 2023 (NDPA) applies to Toju's processing, Toju will comply with the requirements applicable to that processing. Toju will assess whether it must register with the Nigeria Data Protection Commission (NDPC), and will register if it is required to.

Health information is treated as sensitive personal data under the NDPA and is subject to the additional protections applicable to sensitive personal data.

Rights Under the NDPA

Where the NDPA applies, individuals have the rights provided under the Act, subject to its statutory conditions, exceptions, and limitations. These include rights to:

• receive information about the processing of their personal data;
• request access to their personal data and relevant information about its processing;
• request correction or completion of inaccurate or incomplete personal data;
• request erasure where the statutory requirements for erasure are satisfied;
• request restriction of processing in circumstances provided by law;
• object to certain processing;
• withdraw consent where consent is the applicable legal basis for processing;
• receive or request transfer of personal data where the applicable portability requirements are satisfied; and
• exercise applicable rights concerning decisions based solely on automated processing, including profiling.

Withdrawal of consent does not affect processing lawfully carried out before withdrawal. It also does not require Toju to stop processing where another lawful basis permits or requires continued processing.

Cross-Border Processing

Toju is based in Canada and stores information in the United States, as described under International Transfers. As a result, personal data relating to individuals in Nigeria is transferred to and processed outside Nigeria.

Where the NDPA applies, Toju will implement the safeguards and satisfy the requirements governing applicable cross-border transfers. Depending on the circumstances, this may include an applicable adequacy mechanism, contractual safeguards, the individual's consent, or another transfer mechanism permitted by Nigerian law.

Exercising Nigerian Privacy Rights

Requests concerning personal data may be submitted using the contact information section. Toju may verify the requester's identity and, where applicable, authority to act for another person before providing access or making changes.

Toju will handle requests and complaints in accordance with the NDPA and other applicable requirements.

Where an individual is not satisfied with Toju's response or handling of a privacy matter, they may exercise any applicable right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or pursue another remedy available under Nigerian law.

Children and Other Vulnerable Persons

Toju is primarily designed for adults coordinating care and health information. Toju does not intentionally create independent accounts for children without an appropriate legal basis and, where required, authorisation from a parent or lawful guardian.

A parent, guardian, caregiver, or family member who coordinates another person's information must have the legal authority or authorisation required for that activity. Family relationship, caregiving status, or possession of another person's health records does not, by itself, confer unrestricted access to that person's Toju profile.

If an adult cannot give agreement for themselves, for example because of illness or loss of capacity, their legally authorised representative may give agreement on their behalf. Toju may ask for evidence of that authority.

Where Toju becomes aware that personal information has been collected or accessed without the required authorisation, it will take reasonable steps to investigate and address the matter in accordance with applicable law.

Third-Party Services

Toju uses third-party service providers to host, secure, operate, and support the platform, as described in the Service Providers section. These providers may process personal information only as necessary to provide their contracted services and subject to applicable contractual and legal safeguards.

Toju may also link to or integrate with services operated independently of Toju. Those services are governed by their own privacy policies and terms. Where you choose to provide information directly to an independent third party, that party's privacy practices will govern its handling of the information once it is outside Toju's control.

Contact and Privacy Complaints

Questions, privacy requests, complaints, or concerns about Toju's handling of personal information may be directed to:

Toju Health

Privacy Contact: Abolaji Ajeigbe, Founder

Email: abolaji@toju.health

Mailing Address: Toronto, Ontario, Canada. We handle privacy requests by email.

Please do not include unnecessary health information or other sensitive personal information in an initial email. Toju may request additional information to verify identity and, where applicable, authority to act for another person. Toju will review and respond to privacy requests and complaints in accordance with applicable law and its internal privacy procedures.

Individuals may also contact the privacy regulator with jurisdiction over their circumstances. Depending on the applicable law, this may include the Office of the Privacy Commissioner of Canada, a provincial or territorial privacy regulator, or the Nigeria Data Protection Commission. Nothing in this Policy limits an individual's right to contact a regulator directly where that right exists.