Privacy Policy

1. Definitions and Interpretation

In this Privacy Policy, unless the context otherwise requires, the following terms shall have the meanings ascribed to them:

• "Personal Information" means any information relating to an identified or identifiable natural person, as defined under the Nigeria Data Protection Regulation (NDPR) 2019.
• "Processing" means any operation or set of operations performed on Personal Information, whether by automated means, including collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, combination, restriction, erasure, or destruction.
• "Data Controller" means Technox Solutions Ltd, which determines the purposes and means of the processing of Personal Information.
• "Data Processor" means any natural or legal person, public authority, agency, or other body which processes Personal Information on behalf of the Data Controller.
• "Data Subject" means an identified or identifiable natural person whose Personal Information is being processed.
• "Third Party" means any natural or legal person, public authority, agency, or body other than the Data Subject, Data Controller, Data Processor, and persons who are authorized to process Personal Information under the direct authority of the Data Controller or Data Processor.

2. The Data Controller

For the purposes of applicable data protection legislation, the Data Controller is Technox Solutions Ltd, a company registered in Nigeria. We are responsible for determining the purposes and means of processing your Personal Information.

3. Categories of Personal Information Collected

We collect and process the following categories of Personal Information:

3.1. Identity Data

• Full legal names
• Email addresses
• Phone numbers
• Gender
• Date of birth (for individual students)

3.2. Institutional Data

• School names, addresses, and contact details
• School registration and accreditation documents
• Student enrollment and class assignment records
• Teacher employment and subject assignment records
• Academic term and session data

3.3. Educational Data

• Test questions and answer options (including school-created questions)
• Test attempts, scores, and performance analytics
• Progress tracking and assessment results
• Learning history and activity logs
• Subject and topic performance data

3.4. Technical Data

• Internet Protocol (IP) addresses
• Browser types and versions
• Operating systems and device information
• Time zone settings and location data
• Login history and access logs
• Usage patterns and navigation data

3.5. Financial Data

• Payment transaction references (we do not store credit card details)
• Subscription plan information
• Invoices and payment history
• Billing addresses (where applicable)

4. Legal Basis for Processing

We process your Personal Information on one or more of the following legal bases as defined under the Nigeria Data Protection Regulation (NDPR) 2019:

• Consent: You have given us explicit consent to process your Personal Information for a specific purpose.
• Contractual Necessity: Processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject.
• Legitimate Interests: Processing is necessary for the purposes of legitimate interests pursued by us or by a Third Party, except where such interests are overridden by your interests or fundamental rights and freedoms.
• Public Interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

5. How Personal Information is Collected

We collect Personal Information through the following means:

• Direct Collection: When you create an account, update your profile, communicate with us, or use any feature of the Platform.
• School Enrollment: When schools register and enroll students on the Platform.
• Automated Collection: Through the use of cookies, web beacons, and similar technologies as described in Section 9 of this Privacy Policy.
• Third-Party Sources: From third-party service providers, including payment processors and cloud service providers.
• Public Sources: From publicly available sources where permitted by law.

6. Purposes of Processing

We process your Personal Information for the following purposes:

• Platform Provision: To provide, maintain, and improve the Platform and its features.
• Account Management: To create, authenticate, and manage user accounts and profiles.
• Educational Services: To deliver tests, track performance, generate reports, and facilitate learning.
• Communication: To communicate with you regarding the Platform, including support, updates, and marketing communications (with your consent where required).
• Payment Processing: To process payments and manage subscriptions through our payment service providers.
• Research and Development: To analyze usage patterns and improve the Platform, including developing new features and services.
• Security: To maintain the security and integrity of the Platform and prevent fraud or unauthorized access.
• Legal Compliance: To comply with applicable laws, regulations, and legal obligations.

7. Data Sharing and Disclosure

We may share your Personal Information with the following categories of recipients for the purposes specified in Section 6:

• Schools: Student data is shared with the school in which the student is enrolled for educational purposes.
• Service Providers: Third-party service providers who perform services on our behalf, including cloud hosting (AWS), payment processing (Flutterwave), and analytics providers.
• Professional Advisors: Legal, accounting, and other professional advisors where necessary.
• Government Authorities: Law enforcement, regulatory, and other government authorities where required by law or to protect our rights.
• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We require all third-party service providers to implement appropriate technical and organizational measures to protect your Personal Information and to process such information only in accordance with our instructions.

8. International Data Transfers

Your Personal Information may be transferred to, stored, and processed in countries outside Nigeria, including the United States (where our cloud service providers are located). We ensure that appropriate safeguards are in place for such transfers, including:

• Transferring Personal Information to countries that provide an adequate level of protection
• Implementing standard contractual clauses approved by the relevant authorities

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files that are placed on your device by your web browser. We use the following categories of cookies:

• Essential Cookies: These are strictly necessary for the operation of the Platform and cannot be disabled.
• Functional Cookies: These enable the Platform to remember your preferences and provide enhanced functionality.
• Analytics Cookies: These help us understand how users interact with the Platform and improve our services.
• Marketing Cookies: These are used to deliver relevant advertisements and measure the effectiveness of marketing campaigns.

You have the right to refuse the use of non-essential cookies. You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

10. Data Security

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

• Encryption of data in transit using SSL/TLS protocols
• Encryption of data at rest using industry-standard encryption algorithms
• Secure storage of passwords using bcrypt hashing
• Regular security assessments and vulnerability testing
• Access controls to limit access to Personal Information to authorized personnel
• Business continuity and disaster recovery measures
• Employee training on data protection and security

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee absolute security.

11. Data Retention

We retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected, including:

• For the duration of your active account
• To comply with legal obligations
• To resolve disputes
• To enforce our agreements

Upon termination of your account, we will delete or anonymize your Personal Information within a reasonable timeframe, except where we are required to retain such information for legal, regulatory, or legitimate business purposes.

12. Your Rights as a Data Subject

Under the Nigeria Data Protection Regulation (NDPR) 2019, you have the following rights with respect to your Personal Information:

• Right to Access: You have the right to obtain confirmation from us as to whether we are processing your Personal Information and to request access to such data.
• Right to Rectification: You have the right to request the correction of inaccurate Personal Information concerning you.
• Right to Erasure ("Right to be Forgotten"): You have the right to request the deletion of your Personal Information under certain circumstances.
• Right to Restrict Processing: You have the right to request the restriction of processing of your Personal Information in certain circumstances.
• Right to Data Portability: You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format and to transmit it to another Data Controller.
• Right to Object: You have the right to object to the processing of your Personal Information for marketing purposes or on grounds relating to your particular situation.
• Right to Withdraw Consent: Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Information Technology Development Agency (NITDA) or other competent supervisory authority.

To exercise any of these rights, please contact us using the details provided in Section 16. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

13. Children's Privacy

School students are enrolled on the Platform by their schools. The school is responsible for obtaining any necessary parental consent for the collection and processing of student data. Individual students registering on the Platform must be at least 13 years old or have obtained parental consent. Parents or guardians with concerns about their children's data should contact the relevant school directly.

14. Data Breach Notification

In the event of a Personal Information breach that presents a risk to the rights and freedoms of Data Subjects, we will:

• Investigate the breach promptly
• Notify the National Information Technology Development Agency (NITDA) within the timeframe prescribed by law
• Communicate the breach to affected Data Subjects without undue delay
• Take appropriate measures to mitigate the impact of the breach
• Document the breach and remedial actions taken

15. Automated Decision-Making

The Platform does not engage in automated decision-making, including profiling, that produces legal effects or similarly significant effects on Data Subjects. Any automated processes used are limited to providing recommendations and analytics that do not have legal consequences.

16. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or have any concerns regarding our data processing activities, please contact us at:

Technox Solutions Ltd
Email: support@eduhub.com
Website: technoxsolutions.net
Phone: [Insert Phone Number]

We take data protection seriously and will investigate and respond to all complaints and inquiries in a timely and professional manner.

17. Changes to this Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. We will notify you of any material changes by:

• Posting the updated Privacy Policy on this page
• Updating the "Last Updated" date at the top of this page
• Providing notice through the Platform or via email

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your Personal Information.