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LEGAL STATEMENT

Privacy Policy

Last updated: July 2026NDPA & POPIA Compliant

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service, including facilitating bookings for consultations, processing merchandise orders, sending You emails, and understanding how the Website is used through tools such as Google Analytics. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Booking or Consultation means a session You schedule through the Service with a counsellor, coach, or therapist, including any information You provide through Our practitioner-matching questionnaire.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to SCREAM SUPPORT SERVICES, No.10 George Bassey Street, Agungi, Lekki, Lagos State, Nigeria.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to Nigeria, where the Company is established. Given that the Service is offered online, this Policy is also written to reflect the data protection expectations of Our users in South Africa and other jurisdictions.
  • Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
  • Google Analytics means the web analytics service provided by Google that We use to understand how visitors use the Website, as further described in the "Google Analytics" section below.
  • Merchandise means any physical goods offered for sale through the Service.
  • Payment Processor means Paystack, the third-party payment service provider We use to process payments for Bookings and Merchandise, as further described in the "Payment Processing" section below.
  • Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual. We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.
  • Practitioner means a counsellor, coach, or therapist matched to You through the Service to provide a Booking.
  • Sensitive Personal Data means Personal Data revealing or relating to health, mental health, or psychological condition, which receives heightened protection under applicable data protection laws, including data You provide through Our practitioner-matching questionnaire.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company, including Our Payment Processor and Our Email Marketing Platform.
  • Email Marketing Platform means Hostinger, the third-party service We use to send email communications, as further described in the "Emails" section below.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to Screamwomen, accessible from https://screamwomen.com/.
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Applicable Data Protection Laws

Scream is established in Nigeria, and Our users are primarily located in Nigeria and South Africa, though the Service is accessible online and may be used by individuals in other countries. This Privacy Policy is designed to reflect the requirements of:

  • The Nigeria Data Protection Act 2023 ("NDPA") and its implementing regulations; and
  • The Protection of Personal Information Act, 2013 ("POPIA") of South Africa.

Where You access the Service from a different jurisdiction, We apply the practices described in this Policy as a matter of good practice, regardless of whether a specific local law strictly applies, so that all users of Scream receive a consistent standard of protection.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Shipping address, billing address, city, and country (for Merchandise orders)
  • Information You provide through the practitioner-matching questionnaire (Sensitive Personal Data — see below)
  • Booking preferences, such as session format (video or audio) and scheduling details

Booking and Consultation Data

When You book a consultation, We collect the information needed to match You with a suitable Practitioner and to schedule and deliver the session. This includes Your responses to Our matching questionnaire, which cover matters such as Your presenting concern (for example, anxiety, depression, burnout, grief, trauma, or relationship difficulties), duration of the concern, prior therapy history, and Your preferences for the type of support and session format. Because this information may reveal details about Your mental health, We treat it as Sensitive Personal Data and process it only with Your explicit, separate consent, obtained before You complete the questionnaire. This information is shared only with the Practitioner You are matched with, for the purpose of providing Your session, and is not used for marketing purposes.

Merchandise and Order Data

When You purchase Merchandise through the Service, We collect the information needed to fulfil Your order, including Your name, shipping address, billing address, phone number, email address, and a record of the items purchased. This information is shared with delivery/courier partners solely to fulfil Your order, and with Our Payment Processor solely to process Your payment.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Google Analytics

Our Website uses Google Analytics, a web analytics service provided by Google LLC ("Google"), to help Us understand how visitors use the Service — for example, which pages are viewed, how long visitors stay, and what device or browser they use. Google Analytics collects Usage Data of the kind described above, typically through cookies and similar identifiers.

Where required by applicable law, We only activate Google Analytics cookies after You have given Your consent through Our cookie preference tool. You can withdraw Your consent at any time, which will stop future collection of analytics data on Our Website, though it will not affect processing already carried out.

Google may process this data on servers located outside Your country, including in the United States. You can learn more about how Google collects and processes data by reviewing the Google Privacy Policy, and You can opt out of Google Analytics specifically by installing the Google Analytics Opt-out Browser Add-on.

Google Privacy PolicyGoogle Analytics Opt-out Add-on

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies We use include beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

Where required by law, we use non-essential cookies (such as Google Analytics, advertising, and remarketing cookies) only with Your consent, given through Our cookie preferences tool, which is presented before any non-essential cookie is set and allows You to accept or decline by category. You can withdraw or change Your consent at any time using Our cookie preferences tool or through Your browser/device settings. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

    Type: Session Cookies. Administered by: Us.

    These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features, including completing a Booking or Merchandise purchase. They help authenticate users and prevent fraudulent use of accounts.

  • Cookies Policy / Notice Acceptance Cookies

    Type: Persistent Cookies. Administered by: Us.

    These Cookies identify if users have accepted the use of cookies on the Website.

  • Functionality Cookies

    Type: Persistent Cookies. Administered by: Us.

    These Cookies allow Us to remember choices You make when You use the Website, such as remembering your login details or language preference.

  • Analytics Cookies

    Type: Persistent and Session Cookies. Administered by: Google (Google Analytics).

    These Cookies help Us understand how visitors interact with the Website so We can improve it. Set only with Your consent, where required by law.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service.
  • To process Your Booking: to match You with a Practitioner, schedule Your session, and enable the Practitioner to deliver Your consultation.
  • To process Your Merchandise order: to fulfil, ship, and provide customer support for purchases made through the Service.
  • To process payments: to enable Our Payment Processor, Paystack, to process transactions for Bookings and Merchandise on Our behalf.
  • To send You emails: including booking confirmations, receipts, appointment reminders, and, where You have consented, wellness tips, newsletters, and other marketing communications, sent through Our Email Marketing Platform, Hostinger.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased, or of any other contract with Us through the Service.
  • To contact You: by email, telephone, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products, or services You have booked or purchased.
  • To provide You with news, special offers, and general information about goods, services and events We offer, where You have not opted out of such communications.
  • To manage Your requests: to attend and manage Your requests to Us.
  • For other purposes: such as data analysis (including through Google Analytics), identifying usage trends, and evaluating and improving Our Service.

Consent

We rely on different lawful bases to process Your Personal Data, and We obtain Your consent in the following ways:

  • Cookies and Google Analytics: through a cookie banner presented on Your first visit, with non-essential cookies switched off by default. You may accept or decline by category, and change Your choice at any time.
  • Marketing emails: through an unticked checkbox at the point You provide Your email address (for example, during Booking or checkout), separate from any consent to these Terms or to receiving transactional emails. Every marketing email includes an unsubscribe link.
  • Sensitive Personal Data (matching questionnaire): through a standalone, explicit consent step presented before You begin the questionnaire, which explains what information will be collected and that it will be shared with Your matched Practitioner.

You may withdraw any consent given at any time by contacting Us, using the relevant unsubscribe or preference link, or adjusting Your cookie settings. Withdrawing consent will not affect the lawfulness of processing carried out before the withdrawal, and may affect Our ability to provide certain features of the Service, such as matching You with a Practitioner.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data.

Account Information

User Accounts: retained for the duration of Your account relationship plus up to 24 months after account closure.

Booking and Consultation Records

Matching questionnaire responses and session/booking records: retained for up to 24 months after Your last Booking, to support continuity of care and to respond to any dispute, unless a longer period is required by law or requested by You or Your Practitioner for care-continuity reasons.

Merchandise and Payment Records

Order and transaction records, including shipping details and payment references (not full card data, which is held by Paystack): retained for up to 6 years, or such longer period as required by applicable tax, accounting, or consumer protection law.

Email and Marketing Data

Marketing consent records and email engagement data held with Our Email Marketing Platform: retained until You unsubscribe or withdraw consent, plus a short period thereafter to give effect to Your request.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating locations and by the Service Providers described in this Policy. This means Your data may be transferred to, and stored or processed in, countries outside Nigeria or South Africa, including:

  • The United States and other locations where Google processes Google Analytics data;
  • Locations where Paystack, Our Payment Processor, processes payment transactions; and
  • Locations where Hostinger, Our Email Marketing Platform, processes email communications.

Where required by applicable law (including the NDPA and POPIA), We will ensure that such international transfers are subject to appropriate safeguards, such as contractual protections with Our Service Providers, before Your Personal Data is transferred.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You, subject to Our need to retain certain records for legal, accounting, or dispute-resolution purposes as set out above. You may contact Us to request access to, correct, or delete any Personal Data that You have provided to Us, including Booking, Merchandise, or marketing data.

Booking Consultations and Purchasing Merchandise

The Service allows You to book consultations with a Practitioner and to purchase Merchandise. In connection with these transactions:

  • Booking a consultation: You complete a matching questionnaire, which We use to identify a suitable Practitioner. Your responses and contact details are shared with the matched Practitioner for the purpose of providing Your session. Payment for the session is processed through Paystack.
  • Purchasing Merchandise: You provide shipping and contact details needed to fulfil Your order. These are shared with Our delivery/courier partners and Our Payment Processor solely to complete and deliver Your order.
  • Order and booking confirmations, receipts, and related communications are sent to You by email through Our Email Marketing Platform, Hostinger.

We do not use information collected through the matching questionnaire for marketing purposes, and We do not sell Personal Data collected through Bookings or Merchandise orders to third parties.

Payment Processing

All payments made through the Service — whether for a Booking or for Merchandise — are processed by Paystack, a licensed third-party payment service provider. We do not store Your full card, bank account, or other payment credential details on Our own systems; these are collected and processed directly by Paystack in accordance with applicable card industry security standards.

When You make a payment, information such as Your name, email address, phone number, transaction amount, and a payment reference is shared with Paystack to process and confirm Your transaction. Paystack acts as an independent data controller/processor for the payment data it handles, and Paystack's own privacy practices, as set out in its Merchant Privacy Policy, apply to that processing.

If You have questions about how Paystack handles Your payment data specifically, We encourage You to review Paystack's Privacy Policy at https://paystack.com/privacy/merchant, in addition to this Policy.

Emails

Scream sends You emails in connection with the Service. These fall into two categories:

  • Transactional emails: booking confirmations, appointment reminders, order confirmations, receipts, password resets, and other service-related communications. These are necessary for the Service and are not subject to an unsubscribe request, though You may close Your Account to stop receiving them.
  • Marketing emails: wellness content, newsletters, community updates, and promotional offers. These are only sent where You have given Your consent, and every marketing email contains a clear unsubscribe link. You may withdraw consent at any time by using that link or by contacting Us directly.

We use Hostinger as Our Email Marketing Platform to send both transactional and marketing emails. This means Your name and email address, and, where relevant, Your email engagement data (such as whether an email was opened or a link clicked), are processed by Hostinger on Our behalf, in accordance with Hostinger's own privacy practices.

Hostinger Privacy Policy: https://www.hostinger.com/ng/legal/privacy-policy

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency), including the Nigeria Data Protection Commission or South Africa's Information Regulator.

Service Providers

We share Personal Data with the following categories of Service Providers, solely for the purposes described in this Policy:

  • Paystack — payment processing for Bookings and Merchandise.
  • Hostinger — email delivery for transactional and marketing communications.
  • Google (Google Analytics) — website analytics.
  • Practitioners matched to You — to deliver Your Booking.
  • Delivery/courier partners — to fulfil Merchandise orders.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Payment card data is handled directly by Paystack under its own security standards, and We do not store full payment credentials on Our systems. While We strive to use commercially reasonable means to protect the rest of Your Personal Data, including Sensitive Personal Data collected through the matching questionnaire, We cannot guarantee its absolute security.

Your Rights Under Applicable Law

Depending on where You are located, You may have rights under the NDPA, POPIA, or other applicable law, including the right to access, correct, or delete Your Personal Data, the right to object to or restrict certain processing, the right to withdraw consent, and the right to lodge a complaint with the relevant supervisory authority — the Nigeria Data Protection Commission in Nigeria, or the Information Regulator in South Africa. You can exercise any of these rights by contacting Us using the details below.

Children's Privacy

Our Service is not directed at, and does not knowingly collect Personal Data from, anyone under the age of 18. Bookings for consultations, in particular, are intended for adult users. If You are a parent or guardian and become aware that a minor has provided Us with Personal Data, please contact Us so We can take appropriate steps to remove that information.

If We need to rely on consent as a legal basis for processing information relating to a minor, and applicable law requires consent from a parent or guardian, We will require that consent before collecting and using that information.

Contact Us

If you have any questions about this Privacy Policy, or wish to exercise any of Your rights, You can contact us: