Privacy Policy
Last updated: 25 July 2026 · Applies to cover.libertylifeplus.com, our Business and Partner platforms, and the emails we send.
Liberty Life helps individuals, families and businesses in Nigeria get affordable health cover, and enables partners to sell that cover. This policy explains what personal data we collect, why, how we protect it, who we share it with, and the rights you have under the Nigeria Data Protection Act, 2023 (NDPA).
1. Who we are
Liberty Life ("we", "us", "our") is the authorised marketer of health plans underwritten by NEM Health. We are the data controller for the personal data described in this policy. Liberty Life is operated by Liberty Assured Limited, with its office at No 27 Alara Street, off Commercial Avenue, off Herbert Macaulay Road, Yaba, Lagos, Nigeria.
This policy covers everyone who uses our services: members (people with cover, and people cover is bought for), businesses (companies covering their staff), partners (people who sell cover and earn commission), and visitors to our websites.
2. What we collect
We collect the following, depending on how you use Liberty Life:
| Category | What it includes | Who it applies to |
|---|---|---|
| Identity & contact | Name, email, phone number, gender, date of birth, home or business address | Members, buyers, partners, business contacts & staff |
| Health & cover | Chosen plan, dependants/family enrolled, policy number, insurance code, cover status and dates. Claims and care are handled by NEM Health. | Members & covered staff |
| Payment | Bank-transfer references and virtual account details, payment status and amount. We do not store card numbers — card payments are handled by our payment processors. | Anyone who pays |
| Partner & payout | Bank name, account number and account name for commission payouts, referral code, KYC/verification status, sales and downline activity | Partners |
| Business & staff | Company name, RC number, contact details, and the staff roster you upload (names, emails, phones, dates of birth, plans) | Businesses |
| Account | Login email and a securely hashed password, or a one-time email sign-in code | Everyone with an account |
| Communications & consent | Your marketing consent, messages you send us, and whether our emails were delivered or opened | Everyone |
| Technical & usage | IP address, device and browser type, pages viewed, referral/campaign tags (UTM), and cookie identifiers on our marketing pages | Website visitors |
| Location (optional) | Your approximate location, only if you tap "Use my location" in the hospital finder | Anyone using the finder |
We collect this directly from you (forms, sign-up, purchases), automatically (website/app usage), and from partners or employers who enrol you.
3. How we use your data
- Set up and manage your account and cover, and issue your policy and insurance code.
- Take and reconcile payments, and pay partner commissions.
- Enrol staff on behalf of businesses and manage their cover.
- Send you service messages you need — confirmations, insurance codes, renewals, "finish your payment", and account notices.
- Send marketing — only where you have consented, always with a one-click unsubscribe.
- Provide features you ask for, such as finding hospitals near you.
- Keep the service secure, prevent fraud, and meet legal, tax and regulatory obligations.
- Understand and improve how our products and campaigns perform.
4. Our legal bases (NDPA)
- Your consent — for marketing, for processing your health information, and for using your location.
- Performance of a contract — to provide the cover and service you sign up for.
- Legal obligation — to meet tax, anti-fraud, KYC and regulatory requirements.
- Legitimate interests — to secure our platform, prevent fraud, send you the service messages your cover requires, and improve our products, balanced against your rights.
Where we rely on consent, you can withdraw it at any time (see Your rights); this does not affect processing already carried out.
5. Health & sensitive data
Information about your health and cover is sensitive personal data under the NDPA and we treat it accordingly. We process it to arrange and manage your cover, and we share the minimum necessary with NEM Health, the licensed provider that underwrites your plan and delivers your care. We do this on the basis of your explicit consent and to perform your cover contract. We do not use your health data for advertising.
6. Who we share your data with
We never sell your personal data. We share it only with the parties below, and only as needed to run the service:
| Who | Why |
|---|---|
| NEM Health (underwriter) | To issue and manage your cover, your insurance code, and to deliver care and claims at partner hospitals. |
| Payment providers (e.g. Wema Bank, Paystack) | To create payment accounts, take bank transfers and card payments, and reconcile them. They process card details directly under their own security standards. |
| Technology providers | Hosting, database and authentication (Supabase), website hosting (Vercel) and email delivery (Resend) — strictly to run the service on our behalf. |
| Advertising & analytics | On our marketing pages only, Google and Meta tools help us measure and improve campaigns (see Cookies below). |
| Your partner or employer | If a partner enrolled you or an employer covers you, limited details are visible to them to manage your cover. |
| Regulators, law enforcement, advisers | Where required by law, to protect our rights, or in connection with a business transfer. |
Our providers act as our data processors under agreements that require them to protect your data and use it only for the purposes we set.
7. Cookies & analytics
Our apps use essential cookies and local storage to keep you signed in and to remember your preferences — these are required for the service to work. Our marketing and landing pages also use analytics and advertising cookies from Google (Google Ads, Google Analytics) and Meta (Facebook Pixel) to measure reach and campaign performance. You can control cookies through your browser settings, and opt out of ad personalisation through your Google and Meta account settings.
8. Location data
Our hospital finder has an optional "Use my location" feature. If you tap it, your browser shares your approximate coordinates so we can list the nearest hospitals and, to name your area, look it up using OpenStreetMap's service. We do not track your location in the background or store it after the search. If you decline, you can still search by area or state.
9. Marketing & your consent
We send promotional emails only to people who have consented. Every marketing email includes a one-click unsubscribe, and you can opt out any time at cover.libertylifeplus.com/u or by replying to any email. Even if you opt out of marketing, we will still send essential service messages about your cover, payments and account.
10. How long we keep it
We keep your data for as long as you have an account or active cover, and afterwards only as long as needed to meet legal, tax, accounting and dispute-resolution obligations (financial records are generally kept for at least six years). When data is no longer needed, we delete it or irreversibly anonymise it.
11. How we protect your data
We use encryption in transit (HTTPS), access controls and row-level security so people can only see the data they're permitted to, hashed passwords, and reputable, secured infrastructure providers. No system is ever completely secure, but we work to protect your data and will notify you and the regulator of a serious breach as the NDPA requires.
12. International transfers
Some of our technology and advertising providers (for example hosting, email and analytics) may process data on servers outside Nigeria. Where that happens, we take steps required by the NDPA to ensure your data receives an adequate level of protection, such as relying on adequacy, contractual safeguards or your consent.
13. Your rights
Under the NDPA you have the right to:
- Be informed about how we use your data (this policy).
- Access a copy of the data we hold about you.
- Correct data that is wrong or incomplete.
- Delete your data ("right to be forgotten"), where the law allows.
- Restrict or object to certain processing, including direct marketing.
- Port your data — receive it in a portable format.
- Withdraw consent at any time.
- Not be subject to a decision based solely on automated processing that significantly affects you.
To exercise any of these, email privacy@libertylifeplus.com. We respond within the timeframe the NDPA requires. If you're not satisfied, you can lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.
14. Children
Our services are intended for adults (18+). We do not knowingly collect data from children directly. A parent or guardian may enrol a child as a dependant on a family plan, and by doing so confirms they are authorised to provide that child's data.
15. Changes to this policy
We may update this policy from time to time. We'll post the new version here and update the "last updated" date; significant changes will be communicated to you where appropriate.
16. Contact us
Liberty Life — Data Protection contact
Email: privacy@libertylifeplus.com
Address: No 27 Alara Street, off Commercial Avenue, off Herbert Macaulay Road, Yaba, Lagos, Nigeria
Regulator: Nigeria Data Protection Commission — ndpc.gov.ng