1. Identity of the Data Controller
Ornia Limited (formerly Rova HealthTech Limited) is the data controller responsible for your personal data.
2. Scope and Application
This Privacy Policy applies to all personal data we collect, process, store, or transfer in connection with:
- The Ornia autonomous infant monitoring platform, including all hardware components (the Sensor Coin, Guardian Hub), associated firmware, the Ornia mobile application and web platform, and cloud infrastructure;
- The Ornia Limited corporate website and all web-based interfaces operated by us;
- Clinical research, product evaluation, and pilot programmes conducted in partnership with healthcare institutions;
- Communications, enquiries, investor relations, and commercial partnerships;
- Employment applications, contractor agreements, and supplier relationships.
3. Categories of Personal Data We Collect
3.1 Caregiver and Account Data
- Full name, email address, telephone number, and postal address;
- Account credentials (processed in encrypted form; we do not store plaintext passwords);
- Device identifiers, IP addresses, and session data;
- Billing information (processed exclusively through certified third-party payment processors; we do not store raw card data);
- Communication preferences and consent records.
3.2 Infant Physiological and Health Data
⚠ SPECIAL CATEGORY DATA
This data constitutes Special Category Data under Article 9 of the UK GDPR and sensitive personal data under the NDPA 2023. We apply the highest available standard of protection.
- Blood oxygen saturation (SpO₂), including melanin-compensated optical measurements;
- Heart rate, heart rate variability (HRV), and cardiac rhythm indicators;
- Respiratory rate, breathing pattern, and apnoea event data;
- Skin temperature and core temperature estimates;
- Body position, movement, and orientation via inertial measurement;
- Ambient environmental parameters including temperature, humidity, and CO₂ concentration;
- Alert trigger records, threshold breach events, and caregiver response timestamps;
- Device diagnostics, battery state, signal integrity metrics, and firmware event logs.
A critical design principle: Primary safety logic and alert generation execute locally on the device. We do not transfer real-time physiological data to external servers as a prerequisite for safety functionality.
3.3 Data We Do Not Collect
Ornia Limited does not collect or require:
- Racial, ethnic, or national origin data as a condition of product use;
- Religious or philosophical beliefs;
- Sexual orientation or gender identity (beyond voluntary profile fields);
- Financial account credentials or banking passwords.
4. Legal Bases for Processing
We process your personal data only where we have a lawful basis to do so:
5. Purposes of Processing
We process personal data for the following specific, explicit, and legitimate purposes:
- Providing, operating, and improving the Ornia monitoring platform and associated applications;
- Delivering real-time safety alerts, escalation notifications, and caregiver communications;
- Managing user accounts, authentication, and platform access;
- Conducting product validation, safety testing, and firmware update delivery;
- Supporting clinical evaluations, institutional pilots, and academic research partnerships;
- Complying with medical device regulatory obligations under applicable law;
- Responding to support queries, incident reports, and complaints;
- Conducting internal analytics for platform safety improvement (on anonymised or aggregated data only, wherever possible).
We do not sell personal data. We never have and we never will.
We do not use your personal data or infant health data for advertising, targeted marketing profiling, or sale to third parties.
6. Special Protections for Children's Data
The Ornia platform is designed exclusively for the monitoring of infants and young children. All physiological data collected relates to minors. We observe the following mandatory protections:
- Infant physiological data is never processed or stored in identifiable form unless strictly necessary for clinical continuity, caregiver service delivery, or emergency response;
- Aggregated and anonymised infant data used for research cannot be re-linked to any individual infant through our systems by design;
- Caregiver consent is the sole authorised gateway to infant data collection. No data collection commences without verified, explicit caregiver consent;
- Infant data is not shared with commercial third parties for any purpose whatsoever;
- Any request by a government authority or law enforcement body to access infant health data will be resisted to the full extent permitted by law. We will notify affected caregivers of such requests wherever legally permissible;
- Retention of individually identifiable infant health data does not extend beyond the period necessary for the care relationship or research engagement.
8. International Data Transfers
Where personal data is transferred outside the country of collection, we ensure that appropriate safeguards are in place, including:
- Standard Contractual Clauses (SCCs) approved by the UK ICO or the European Commission, as applicable;
- Adequacy decisions recognising the destination country as providing equivalent data protection;
- Data processing agreements incorporating obligations no less stringent than those imposed on us by applicable law;
- Transfer Impact Assessments (TIAs) conducted and documented for each transfer mechanism.
No infant physiological data is transferred to any jurisdiction that has not satisfied our internal transfer risk assessment. Where no adequate safeguard can be established, the transfer will not proceed.
9. Data Security
We implement technical and organisational security measures proportionate to the sensitivity of the data we process:
🔐 End-to-end encryption
TLS 1.3 or equivalent for all physiological data in transit
💾 Encryption at rest
AES-256 or equivalent standards for infant health data
👤 Access controls
Role-based access ensuring only authorised personnel access identifiable personal data
🔑 MFA
Multi-factor authentication for all administrative and clinical data system access
🔍 Penetration testing
Regular independent vulnerability assessments and security testing
📋 Incident response
Formal procedures with mandatory notification timelines compliant with NDPA Section 40 and UK GDPR Article 33
10. Data Retention
We retain personal data only for as long as necessary for the purposes for which it was collected:
| Data Category | Retention Period |
|---|---|
| Active Account Data | 5 years after account closure |
| Infant Physiological Data | 90 days after account closure (identifiable); longer with caregiver consent for research |
| Clinical Research Data | 10–15 years following conclusion of the research programme |
| Device Diagnostic & Safety Logs | 7 years for regulatory compliance and product liability purposes |
| Marketing Communications Data | Until consent withdrawn or 3 years of inactivity, whichever is earlier |
11. Your Rights as a Data Subject
Subject to applicable law, you have the following rights in relation to your personal data:
Right of Access
Request a copy of the personal data we hold about you and information about how we process it.
Right to Rectification
Request correction of inaccurate or incomplete personal data.
Right to Erasure
Request deletion of your personal data where we no longer have a lawful basis to retain it.
Right to Restriction
Request that we limit how we use your data in certain circumstances.
Right to Portability
Where processing is based on consent or contract, request your data in a structured, machine-readable format.
Right to Object
Object to processing based on legitimate interests or for direct marketing purposes.
Right to Withdraw Consent
Withdraw consent at any time without affecting the lawfulness of prior processing or the continued availability of core safety functionality.
Automated Decision-Making
We do not make decisions solely by automated means that produce significant effects. Human clinical oversight is maintained in all alert escalation pathways.
To exercise any of these rights, contact us at info@rovatechltd.co.uk. We will respond within 30 days.
If unsatisfied with our response, you may lodge a complaint with:
12. Regulatory and Clinical Compliance
The Ornia ecosystem is designed for regulatory submission as a medical device. Our data processing activities are structured to be compatible with:
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Where we make material changes, we will notify registered users by email and post an updated Policy with a revised effective date. We will not apply material changes retrospectively to data collected under a prior version of this Policy without obtaining fresh consent where required.
15. Contact and Data Protection Enquiries
All data protection queries, subject access requests, consent withdrawals, and regulatory correspondence should be directed to:
Ornia Limited (formerly Rova HealthTech Limited)
Email: info@rovatechltd.co.uk
Website: rovatechltd.co.uk
Data Protection Lead: Raphael G.U. Eriemo, Founder and Director
Document Reference: MAL-LEG-PP-001 · Version 1.0 · Effective Date: 16 May 2025
Jurisdiction: Federal Republic of Nigeria | United Kingdom
This Privacy Policy is a legally binding document of Ornia Limited. — The guardian that never sleeps.