NOTICE VERSION 2026-09-26
Privacy notice
This explains what Pulsive holds about you, why, who sees it, how long we keep it, and what you can make us do about it. It is written to be read, not to be skipped.
1. Who we are
Pulsive is operated by [REQUIRED BEFORE LAUNCH: registered company name], a company registered in Nigeria with the Corporate Affairs Commission, certificate number [REQUIRED BEFORE LAUNCH: RC number]. We are the data controller for the information described here.
You can reach us at [REQUIRED BEFORE LAUNCH: email address]. Our Data Protection Officer is [REQUIRED BEFORE LAUNCH: DPO name and contact]. Where we operate through a representative, that representative is [REQUIRED BEFORE LAUNCH, only if you appoint one].
2. What we collect, and what we deliberately do not
To put you in touch with a hospital that needs your blood type, we hold:
- your name, phone number, state and local government area;
- your blood type;
- your age band (for example 25–34), not your date of birth;
- records of which blood requests you have responded to.
To confirm you are who you say you are, we check a national identity number once. Then:
- We do not keep your national identity number. It is checked with our verification provider and then discarded.
- We keep a keyed cryptographic digest of it, which cannot be reversed without a secret held only on our server. A plain hash of an 11 digit number would be trivially brute forced, so we do not use one.
- We do not keep the last four digits of it, and we never store your exact date of birth.
If you share your location, we use it once to work out your state and local government area, and to tell you how far a hospital is. We do not store your coordinates. Location is optional and off by default.
3. Why we are allowed to use it, and what for
We rely on your consent, given separately for each purpose, because health information is sensitive data under the Act. Consent to be matched to a blood request is not consent to share your location, and neither is consent to be contacted. You can withdraw any of them at any time, and withdrawing is as easy as giving.
- Identity verification — checking your identity once when you register.
- Donor registry — keeping you in the register of donors.
- Blood matching — telling you about requests matching your blood type and state.
- Hospital sharing — passing your name and number to a hospital you have said you will donate to.
- Notifications — sending you a message about a matching request.
- Location — optional; telling you about requests near you.
Records that a donation actually happened are kept with your identity removed, because blood safety and haemovigilance require the event to be recorded. We keep the fact; we do not keep whose it was, once you have asked us to erase you.
4. Who else sees it
- Our SMS provider, which sends the message and passes back whether it was delivered. It acts as a processor on our instructions.
- Our identity verification provider, which checks your identity number at the moment you register.
- Our hosting provider, [REQUIRED BEFORE LAUNCH: host and its country].
- A hospital, but only your name, blood type and phone number, and only after you have responded to its request.
- Nobody else. We do not sell data, and we do not share it for advertising.
If any of these providers are outside Nigeria, we rely on [REQUIRED BEFORE LAUNCH: the transfer mechanism, or confirm all are hosted in Nigeria].
5. How long we keep it
Your donor record is kept while you stay registered, and for [REQUIRED BEFORE LAUNCH: retention period] after you ask us to remove it. Consent records are kept as evidence that you agreed.
6. Your rights
You can ask us to:
- confirm whether we hold anything about you, and give you a copy;
- correct something that is wrong;
- delete what we hold about you;
- stop using your data while a dispute is resolved;
- give you your data in a machine readable file, to take elsewhere;
- withdraw consent, for any purpose, without giving a reason.
Every one of these needs a fresh identity check first, so that nobody can use this form to look up somebody else. Where a correction is our mistake, we fix it at no cost to you.
To make a request, contact [REQUIRED BEFORE LAUNCH: email address] or use the endpoints documented in the project README.
7. Decisions made automatically
We do not make decisions about you by automated means, and we do not build a profile of you. We do use automated matching: your blood type and state are compared against open requests in order to show you the ones that apply to you. That is a straightforward comparison, it has no effect on your rights, and you can ask us to stop it by withdrawing blood matching consent.
8. Complaints
If you are not satisfied with how we have handled your data, write to [REQUIRED BEFORE LAUNCH: email] first. You also have the right to complain to the Nigeria Data Protection Commission at ndpc.gov.ng. Nothing in these terms limits your right to complain or to take a case to a Nigerian court.
9. Children
Only people aged 18 to 65 can donate blood, and Pulsive does not accept or display donors under 18. Where a person is under 18, only a registered Blood Establishment may decide whether they may donate, with a parent or guardian present.
10. Cookies
Pulsive sets no cookies. It uses only your browser's local storage, to keep you signed in and to remember your filters. Clearing your browser data removes them, and nothing we store there leaves your device except the information you type into a form.
11. Security
Identity numbers are discarded after checking. What remains is keyed so it cannot be reversed from a leaked database. Requests over the network are encrypted in transit, and access to records is limited to staff who need it. If a breach affects your data we will notify the Data Protection Commission within 72 hours and tell you straight away where the risk to you is serious.
12. Changes
When this notice changes materially we will show the new version number at the top of the page and ask you to agree again where the change needs your consent.