CloseBy Privacy Policy
Last Updated: 9 October 2026
This Privacy Policy explains how CloseBy collects, uses, shares and protects personal information. By using CloseBy’s website or services, you confirm that you have read this Policy. It sits alongside the CloseBy Care Service Terms and the Refund & Cancellation Policy.
1. Who We Are
CloseBy is operated by NQLB Limited (“CloseBy”, “we”, “us”). We decide how and why your personal information is used, which makes us the data controller. NQLB Limited complies with the Nigeria Data Protection Act 2023 and the requirements of the Nigeria Data Protection Commission (NDPC).
Address: 483C Omotunde Akinsola Street, Ikeja, Lagos, Nigeria
Email: [email protected]
Website: www.closebyhome.com
2. Who This Policy Covers
- Visitors to our website;
- Payers, meaning people who book or fund Services for someone else; and
- Service Users, meaning the older adults who receive Services.
Terms such as Payer, Service User, Services and Healthcare Provider carry the same meaning as in the Care Service Terms.
3. Information We Collect
| Who | What we collect | Where it comes from |
|---|---|---|
| Website visitors | Email address when you join a list or request details; basic technical data your browser sends when it loads our pages, and website usage data collected through Google Analytics (pages viewed, approximate location, device and browser type) | You, and your browser |
| Payers | Name, email address, phone number, relationship to the Service User, payment status and receipt details. Card details go directly to Stripe and stay with Stripe | You, and Stripe |
| Service Users | Name, age, home address and location in Nigeria, phone number, emergency contact, care preferences, consent and information sharing choices | The Payer, the Service User and family contacts |
| Service Users (health information) | Health concerns shared with us for a visit, visit outcomes and reports prepared by the Healthcare Provider, and follow up notes | The Service User, the Payer, and the Healthcare Provider |
| Everyone | Messages and emails you send us, and records of our calls and WhatsApp conversations with you | You |
Health information is sensitive personal data. We handle it with extra care, as described in section 5.
4. How We Use Information
- to book, coordinate and confirm visits and match a suitable Healthcare Provider;
- to take payment and send receipts;
- to share visit updates with the Payer, within the limits the Service User has chosen;
- to contact you about your booking, including by email, phone and WhatsApp;
- to look after health and safety, including emergencies and safeguarding concerns;
- to respond to questions and complaints;
- to keep our records, meet legal duties and prevent fraud; and
- to improve CloseBy, using summarised information wherever possible.
We send marketing emails only to people who ask to hear from us, and every email carries an unsubscribe link.
5. Our Legal Basis
Under the Nigeria Data Protection Act 2023, and the UK GDPR where it applies to UK based Payers, we rely on the following.
- Contract: to deliver the Services you book and pay for.
- Consent: for health information and for sharing it with the Payer. The Service User gives this choice through the Elder Consent, Privacy & Authorisation Form, and may change or withdraw it at any time.
- Legitimate interests: to run, secure and improve CloseBy, in ways that respect your rights.
- Legal obligation: to meet tax, accounting, regulatory and safeguarding duties.
- Vital interests: to protect someone’s life in an emergency.
Paying for care does not give the Payer access to the Service User’s health information. The Payer receives clinical details only where the Service User has authorised it or the law permits it.
6. Who We Share Information With
- Healthcare Providers who deliver the visit, so they can give safe care. They hold their own clinical records and have their own professional duties of confidentiality.
- Service providers who help us operate CloseBy under written terms: Stripe for payments, Airtable for our booking and customer records, Zapier for automation, Twilio and WhatsApp for messaging, Cloudflare for website hosting, and Google Analytics for website usage statistics. Our website also loads fonts from Google Fonts.
- Emergency services and authorities where there is a serious risk to someone’s safety, or where the law requires it.
- Professional advisers such as accountants and lawyers, under duties of confidentiality.
CloseBy keeps your information out of sales to third parties and keeps it out of advertising networks.
7. Transfers Outside Your Country
Many of our service providers operate outside Nigeria and the UK, including in the United States, where Google, Stripe, Airtable and Zapier operate. Where information moves across borders, we use providers that offer appropriate safeguards, such as contractual protections, in line with the Nigeria Data Protection Act 2023 and the UK GDPR.
8. How Long We Keep Information
- Payment and accounting records: 6 years.
- Service and care coordination records: 6 years after the last Service.
- Website sign ups and enquiries: until you unsubscribe, or 24 months after your last contact, whichever comes first.
- Messages and call notes: 2 years after the last contact.
We delete or anonymise information once the period ends, unless the law requires us to keep it longer.
9. How We Protect Information
We limit access to people who need it for their role, use trusted providers with security controls, and share health information only with the people who need it for care. No online system is completely secure. If a breach affects your rights, we will tell you and the relevant regulator within the time the law sets.
10. Your Rights
You may ask us to:
- give you a copy of your information;
- correct information that is wrong or incomplete;
- delete your information, where the law allows;
- restrict or object to certain uses;
- move your information to another provider; and
- withdraw consent at any time, which leaves earlier lawful use unaffected.
Email [email protected] and we will respond within 30 days. A Payer may ask about their own information. Requests about a Service User’s health information are handled with the Service User’s involvement.
You may also complain to the Nigeria Data Protection Commission (www.ndpc.gov.ng), or, if you live in the UK, to the Information Commissioner’s Office (www.ico.org.uk). We would welcome the chance to put things right first.
11. Cookies and Website Analytics
Our website uses Google Analytics to understand how visitors use our pages, so we can improve them. Google Analytics sets cookies that collect information such as pages viewed, time on site, approximate location and device type. We use this information in summary form and use it for no advertising purposes.
You can control this in three ways: adjust your browser settings to block or delete cookies, install Google’s opt out add on at tools.google.com/dlpage/gaoptout, or tell us at [email protected]. Where the law asks for your agreement before analytics cookies are set, we ask for it through a notice on our website.
Our website runs without advertising cookies.
12. Children
CloseBy’s Services are for adults. Our website is aimed at adults who arrange care for older relatives.
13. Changes to This Policy
We may update this Policy from time to time. The latest version is always at www.closebyhome.com/privacy.html with its date at the top. If a change materially affects how we use your information, we will give reasonable notice.
14. Contact Us
NQLB Limited
483C Omotunde Akinsola Street, Ikeja, Lagos, Nigeria
[email protected]