Your conversations.
Your privacy.
Our commitment.

Tangiko Video Relay Service (VRS) is an inclusive communication platform designed to help Deaf and hard-of-hearing persons communicate with hearing persons through sign language interpretation and related digital communication technologies.

Tangiko aims to improve access to healthcare and other essential services for persons with disabilities, particularly within Akwa Ibom State, Nigeria, and beyond.

We recognise that privacy, confidentiality, dignity, and trust are essential to effective communication, especially when users seek medical attention or discuss personal, family, legal, financial, or other sensitive matters.

This Privacy Policy explains how Tangiko collects, uses, stores, protects, shares, and otherwise processes personal information when you access our website, mobile application, video relay services, interpreter booking facilities, or other services provided through the Tangiko platform.

By using Tangiko, you acknowledge that you have had an opportunity to read this Privacy Policy.

This Privacy Policy applies to:

• ✓Deaf and hard-of-hearing users of Tangiko.
• ✓Hearing persons communicating through Tangiko.
• ✓Registered sign language interpreters.
• ✓Healthcare professionals and healthcare facilities using Tangiko.
• ✓Organisations and institutions that use Tangiko for accessible communication.
• ✓Visitors to the Tangiko website and other individuals whose information is processed through the service.

This policy applies to personal information collected online and through the operational delivery of Tangiko services.

Where a healthcare facility or another organisation uses Tangiko under a separate agreement, additional contractual privacy and data-processing terms may also apply.

Depending on the features you use, Tangiko may collect the following categories of information.

3.1 Personal Identification Information

This may include:

• ✓Full name.
• ✓Username and account identification number.
• ✓Email address and telephone number.
• ✓Age or date of birth, where necessary.
• ✓Preferred communication method and language.
• ✓Account registration and verification information.

We will seek to collect only information that is reasonably necessary for the relevant service.

3.2 Disability and Accessibility Information

To provide accessible communication, Tangiko may process information about a user's preferred sign language, accessibility requirements, communication preferences, and related accommodation needs.

We will handle information that reveals or relates to a person's disability with appropriate confidentiality and safeguards.

3.3 Health and Medical Information

Where Tangiko is used to facilitate healthcare communication, users may disclose or communicate information concerning:

• ✓Medical conditions and symptoms.
• ✓Medical consultations and treatment discussions.
• ✓Prescriptions, referrals, and appointments.
• ✓Medical history and care instructions.
• ✓Other information disclosed during healthcare-related communication.

Health information is particularly sensitive. Tangiko will process it only for specified, legitimate purposes and under an applicable lawful basis, with additional safeguards appropriate to its sensitivity.

Tangiko is a communication and interpretation service. Unless expressly stated in the applicable service terms, it is not itself a substitute for professional medical advice, diagnosis, or treatment.

3.4 Video, Audio, and Sign Language Communication

When you use video relay services, the platform may process:

• ✓Live video and audio streams.
• ✓Sign language movements and visual communication.
• ✓Interpreter-user interactions.
• ✓Call connection times, duration, and status.
• ✓Technical information needed to establish and maintain calls.

Tangiko's default privacy commitment should be that live calls are not recorded or stored unless a specific, lawful, transparently disclosed feature requires it and the necessary safeguards and permissions are in place.

If recording, transcription, AI analysis, or other processing of call content is introduced, Tangiko will clearly disclose the purpose, legal basis, retention period, and relevant choices before the feature is used.

3.5 Interpreter Booking and Service Records

For scheduled interpretation sessions, we may collect:

• ✓Booking date and time.
• ✓Requested interpretation language.
• ✓Appointment type and relevant accessibility requirements.
• ✓Assigned interpreter and booking status.
• ✓Cancellation and rescheduling information.
• ✓Service quality feedback and complaints.

We will avoid collecting unnecessary clinical details when basic booking information is sufficient.

3.6 Payment Information

Where Tangiko charges for services, we may process payment status, transaction references, amounts, dates, and billing records.

Payments may be processed by third-party payment service providers. Tangiko will not intentionally collect or retain complete payment-card security credentials when these can be handled securely by the payment provider.

3.7 Technical and Usage Information

We may collect technical information such as:

• ✓IP address and device type.
• ✓Browser or application version.
• ✓Operating system.
• ✓Login activity and security logs.
• ✓Connection quality and error reports.
• ✓Features used and general platform usage statistics.

This information helps us maintain security, improve accessibility, troubleshoot problems, and evaluate service performance.

Tangiko may use personal information for the following purposes:

• ✓Account management: Creating, verifying, and maintaining user accounts.
• ✓Video relay communication: Connecting users with interpreters and facilitating communication.
• ✓Healthcare accessibility: Supporting communication between Deaf patients, healthcare professionals, and healthcare facilities.
• ✓Interpreter booking: Managing scheduled appointments, availability, cancellations, and reminders.
• ✓Payments and administration: Processing service payments and maintaining appropriate financial records.
• ✓Service improvement: Assessing platform reliability, accessibility, interpretation quality, and user experience.
• ✓Security and fraud prevention: Detecting unauthorised access, abuse, fraud, and technical threats.
• ✓Customer support: Responding to complaints, questions, and requests.
• ✓Legal compliance: Meeting applicable legal, regulatory, and lawful reporting obligations.
• ✓Research and analytics: Producing appropriately aggregated or de-identified statistics to improve inclusive communication and healthcare access.

Tangiko will not use personal information for purposes that are incompatible with the original purpose of collection without an appropriate lawful basis and any additional notice or consent required by law.

Tangiko will process personal information in accordance with the Nigeria Data Protection Act 2023 and other applicable laws.

Depending on the circumstances, processing may be based on:

• ✓The user's consent.
• ✓The performance of a contract or steps requested before entering a contract.
• ✓Compliance with a legal obligation.
• ✓Protection of vital interests where legally applicable.
• ✓A legitimate interest that does not override the individual's rights and freedoms.
• ✓Another lawful basis recognised by applicable data protection law.

For sensitive information, including health information and information relating to disability, Tangiko will identify and document the additional lawful condition required for processing.

Where consent is the applicable basis, it must be appropriately informed and freely given, and users must be able to withdraw it where required by law. Withdrawal does not invalidate processing lawfully carried out before withdrawal.

Consent to use the Tangiko service will not automatically constitute consent to record calls, use medical information for research, or train artificial intelligence systems.

Tangiko recognises the confidential nature of interpreted communication.

6.1 Live Calls

Live relay sessions may involve discussions about health, personal relationships, employment, banking, education, legal matters, and other private affairs.

Tangiko will implement appropriate technical and organisational safeguards to prevent unauthorised access to live calls.

Where technically feasible, call content will be transmitted securely, and access will be restricted to participants and authorised personnel who need access for a legitimate, disclosed purpose.

6.2 Interpreter Confidentiality

Tangiko will establish confidentiality obligations for interpreters and relevant personnel.

Interpreters must not disclose private information obtained during sessions except where disclosure is authorised, legally required, or otherwise permitted by applicable law.

Interpreters must not make unauthorised recordings, screenshots, copies, or disclosures of interpreted sessions.

6.3 Exceptional Disclosure

Confidential information may be disclosed where required or permitted by applicable law, such as in response to a valid legal order or where a legally recognised exception applies.

Where legally permissible, Tangiko will limit disclosure to the information necessary for the relevant purpose.

Tangiko may use artificial intelligence to support sign language interpretation, improve accessibility, assist with service delivery, or analyse platform performance.

Where AI features are used, Tangiko will take reasonable steps to:

• ✓Explain the relevant AI processing in accessible language.
• ✓Limit processing to specified purposes.
• ✓Apply safeguards to sensitive personal information.
• ✓Assess the accuracy and limitations of AI-generated interpretations.
• ✓Restrict access to AI processing outputs.
• ✓Avoid unnecessary retention of video, audio, images, or derived data.

Tangiko will not use identifiable user video, audio, sign language recordings, medical conversations, or other sensitive communication to train or improve AI models unless a valid legal basis exists and all required notices, permissions, safeguards, and any necessary consent are in place.

Where a feature involves significant automated decisions affecting a person, Tangiko will provide the information and safeguards required by applicable law, including any applicable rights relating to human review or challenge.

AI-assisted interpretation may make mistakes. Users and healthcare professionals should confirm critical medical information rather than relying solely on an automated interpretation.

Tangiko does not intend to make users' personal information publicly available or disclose it indiscriminately.

Information may be shared with the following categories of recipients when necessary and lawful:

8.1 Interpreters

An assigned interpreter may receive the information necessary to provide the requested interpretation service, such as the session time, communication language, and connection details.

8.2 Healthcare Providers

Where a user engages in a healthcare consultation, information may be accessible to the participating healthcare professional to the extent necessary for communication and care.

Tangiko will not automatically make all user account records available to every healthcare facility.

8.3 Technology and Service Providers

These may include providers of secure hosting, video communication infrastructure, customer support, analytics, cybersecurity, and payment processing.

Such providers must be subject to appropriate contractual protections and access restrictions.

8.4 Government and Regulatory Authorities

Information may be disclosed when required by law or through a valid legal process, or where another lawful basis permits disclosure.

8.5 Other Recipients With Permission

Information may be shared with other persons or organisations where the user has provided appropriate authorisation or where another lawful basis applies.

Tangiko will not sell personal information to third parties.

Some technology providers may store or process information outside Nigeria.

Where personal information is transferred internationally, Tangiko will comply with applicable Nigerian data protection requirements, including applicable transfer conditions and safeguards.

We will assess relevant providers and transfer arrangements to ensure that personal information receives an appropriate level of protection.

Where required, users will be informed about relevant international transfers and their associated safeguards.

Tangiko will retain personal information only for as long as reasonably necessary for the purposes for which it was collected, unless a longer period is required or permitted by law.

Retention periods will be established for different categories of information, including:

• ✓User account information.
• ✓Interpreter registration and verification records.
• ✓Booking and service administration records.
• ✓Payment and accounting records.
• ✓Security logs.
• ✓Complaints and incident records.
• ✓Health-related records, where applicable.

Live video and audio streams should not be retained after a session unless an expressly disclosed and lawful operational purpose requires retention.

Where information is no longer required, Tangiko will securely delete it, destroy it, or irreversibly anonymise it, subject to applicable legal and technical requirements.

Tangiko will implement appropriate technical and organisational measures to protect personal information against accidental loss, destruction, unauthorised access, alteration, disclosure, or misuse.

Depending on the risks and the service architecture, safeguards may include:

• ✓Encryption in transit and, where appropriate, at rest.
• ✓Secure account authentication and access controls.
• ✓Role-based access for interpreters, administrators, and support staff.
• ✓Secure handling of video communication and session credentials.
• ✓Security monitoring and audit logs.
• ✓Regular vulnerability assessments and software updates.
• ✓Staff confidentiality obligations and privacy training.
• ✓Backup protection and secure deletion procedures.
• ✓Incident response and business continuity arrangements.

No online service can guarantee absolute security. Tangiko will nevertheless take reasonable steps to maintain appropriate protection and respond to security incidents.

If a personal data breach occurs, Tangiko will assess the incident promptly, take reasonable steps to contain it, investigate its impact, and prevent recurrence.

Where notification is required, Tangiko will notify the Nigeria Data Protection Commission and affected individuals in accordance with applicable legal requirements and timelines.

Communications to affected users will explain the nature of the breach, likely consequences, steps taken, and recommended protective actions, where appropriate.

Subject to applicable law and any relevant exceptions, individuals may have the right to:

• ✓Access: Request confirmation of whether Tangiko processes their personal information and obtain access to it.
• ✓Correction: Request correction of inaccurate or incomplete information.
• ✓Deletion: Request erasure of personal information where the applicable legal conditions are satisfied.
• ✓Restriction: Request restriction of certain processing activities.
• ✓Objection: Object to processing where the law grants that right.
• ✓Withdraw consent: Withdraw consent where processing relies on consent.
• ✓Data portability: Request a copy of qualifying personal information in a structured, commonly used, machine-readable format where applicable.
• ✓Complain: Lodge a complaint with the relevant data protection authority.
• ✓Challenge automated processing: Exercise any applicable rights relating to decisions made solely by automated means.

These rights are subject to applicable legal requirements and exceptions. For example, some records may need to be retained to comply with legal obligations or establish, exercise, or defend legal claims.

Tangiko will provide reasonable assistance in exercising these rights and will respond within the time limits prescribed by applicable law.

Users may submit a privacy request through the contact details provided at the end of this policy.

To protect against unauthorised disclosure, Tangiko may request reasonable information to verify the identity or authority of the person making the request.

We will not require unnecessary personal information for verification.

Where a request is made on behalf of another person, Tangiko may request evidence of lawful authority, subject to applicable law.

The Tangiko website may use cookies or similar technologies to support essential functions, maintain user sessions, improve security, remember accessibility preferences, and understand website performance.

Where non-essential cookies or tracking technologies require consent, Tangiko will obtain consent before activating them and provide an appropriate mechanism for managing preferences.

Users may also manage cookies through their browser settings, although disabling certain cookies may affect website functionality.

Tangiko should publish a separate cookie notice if it uses analytics, advertising, or other non-essential tracking technologies.

Tangiko may be used by children or young persons who need accessible communication services, including healthcare communication.

Where children use the platform, Tangiko will apply appropriate safeguards and comply with applicable Nigerian laws relating to children's personal information, consent, parental or guardian involvement where required, and protection of the child's best interests.

The platform will not knowingly collect unnecessary information from children.

Where a child requires an interpreter during a healthcare consultation, the information shared and the participation of parents, guardians, or other representatives will be handled according to applicable law, professional obligations, and the child's circumstances.

Users are encouraged to:

• ✓Keep their account credentials confidential.
• ✓Use secure devices and trusted internet connections where possible.
• ✓Avoid sharing unnecessary sensitive information through non-secure channels.
• ✓Log out of shared devices after using Tangiko.
• ✓Notify Tangiko promptly of suspected unauthorised account access.
• ✓Ensure that information submitted about another person is lawfully provided.

These responsibilities do not reduce Tangiko's own obligations to protect personal information.

Tangiko may contain links to third-party websites or integrate external services, including payment providers and video communication tools.

Those services may operate under their own privacy policies and terms.

Tangiko is not responsible for the privacy practices of independent third parties outside its control. Users should review the relevant privacy notices before providing information directly to those providers.

Tangiko will assess third-party services used in its own operations and implement appropriate contractual and technical safeguards where required.

Users who believe that their personal information has been handled improperly may contact Tangiko to raise a complaint.

We will investigate complaints fairly and take appropriate corrective action where necessary.

If the matter remains unresolved, individuals may refer the complaint to the Nigeria Data Protection Commission or another competent authority, as applicable.

Nothing in this policy limits rights or remedies available under applicable law.

Tangiko may update this Privacy Policy to reflect changes in its services, technology, legal obligations, or data protection practices.

The updated version will be published on www.tangiko.com with a revised “Last Updated” date.

Where a change materially affects how sensitive personal information is processed, Tangiko will provide additional notice and obtain consent where required by law.

Continued use of Tangiko will not, by itself, substitute for consent where fresh consent is legally required.

For questions, privacy requests, complaints, or concerns about the handling of personal information, please contact:

Tangiko Video Relay Service (VRS)

Website: https://www.tangiko.com

Data Protection Team

Email: privacy complaints@tangiko.com

Postal Address: 15 Okon Essien Lane, Uyo

Please include “Privacy Request” or “Data Protection Complaint” in the subject line of written communications.

Tangiko is committed to promoting dignity, accessibility, confidentiality, and equal participation for Deaf and hard-of-hearing persons.

We recognise that accessible communication must also be safe communication. Our privacy practices should therefore protect the confidentiality of users, support responsible healthcare communication, and maintain trust between users, interpreters, healthcare professionals, and other participating organisations.

By implementing appropriate privacy safeguards and complying with applicable data protection laws, Tangiko seeks to provide a trustworthy and inclusive communication service.

Tangiko VRS — Bridging Communication, Advancing Inclusion.