This Privacy Policy forms an integral part of the Enrolment Agreement accessible on our website at www.etutors.ng. It also applies to any agreement wherein reference is made to this privacy policy and governs the collection, use, disclosure, and safeguarding of personal data obtained through the use of the website.
eTutors Nigeria Limited (hereinafter “eTutors”, “we”, “us”, or “our”) is committed to safeguarding your privacy and recognises the importance of protecting personal data. This policy outlines our practices concerning the processing of personal data and the rights available to data subjects under applicable law.
DEFINITIONS
For the purposes of this Policy:
“Personal data” means, unless otherwise defined by applicable law, any information which identifies or can reasonably be used to identify an individual, including but not limited to name, contact details, educational background, and IP address, unless otherwise defined by applicable law. For clarity, this Privacy Policy does not apply to our employees, job applicants, and independent contractors.
“The site” refers to our web-based platform accessible via www.etutors.ng and its associated subdomains.
“Subdomains” include all third-level domains under www.etutors.ng, including temporary pages bearing the contact details of the Site Administrator.
“An IP address” is the unique network address of the site in the computer network through which the user gets access to the Site.
“Cookies” are small data files transmitted by a web server, stored on the user’s device, and subsequently sent back with each HTTP request to the server.
“Services” mean all educational products and services provided by eTutors via the Site.
“Processing of personal data” is any action (operation) or a set of actions (operations) carried out while using automated tools or without the use of those with personal data, including obtaining, recording, systemization, accumulating, keeping, rectification (updating, modificating), extraction, utilization, transmission (distribution, provision, accessing), depersonalization, blocking, removing, destruction of personal data.
CONSENT AND SCOPE
Keeping the privacy of personal data is a mandatory requirement for the Administration of the Site or other person who has gained access to it, and the dissemination of personal data is not allowed without the permission of the subject of personal data or the existence of other legal reasons for that. By accessing our Site or using our services, you consent to the practices set out in this Policy, which may be amended from time to time. This Policy is incorporated by reference into our Terms of Use.
USERS UNDER THE AGE OF 16
For users below the age of 16, we require verifiable consent from a parent or legal guardian before collecting any personal data. Parents or guardians may request access to the data collected, instruct us to delete such data, or prevent further data collection. Such request must must include sufficient proof of identity and relationship to the child.
INFORMATION WE COLLECT
We collect information through the sources described below.
Information You Provide to Us
We collect personal and non-personal information from you (such as your parents’ or guardians’ name, address, email address, phone number, school name, grade level, year of graduation, date of birth, the test that you are interested in preparing for, test scores, academic interests, transcripts, photos, essays, applications to schools, employer name and job title) when you:
register or create an account on our Site;
call us;
purchase and use our services.
provide or send us messages, documents, and other files and content in the course of your use of our services;
enter sweepstakes or other promotions;
submit online forms or testimonials and respond to surveys or questionnaires;
register for or attend events we host, sponsor, or participate in; or
when you provide us with information by other means.
Data from Third Parties
We may receive data from partner institutions, marketing affiliates, vendors or service providers, licensees and educational bodies.
Information Collected Automatically
We may collect technical data such as IP address, browser type, device details, cookies and usage logs, session recordings and analytics, submitted assessments and feedback. We do not store any payment information; all transactions are processed by third-party financial service providers.
WHY DO WE COLLECT PERSONAL DATA?
We process your data in accordance with the Nigerian Data Protection Regulation. We only use your personal information for the purposes of this Privacy Policy and with your agreement.
If we wish to use your personal information for other purposes, we will obtain your permission to use it. Without your agreement, we will not use your data for other purposes.
Data Type: Personal Data Use Purposes: Reason for using your Data:
Your email User identification and service delivery. Contractual necessity and the provision of the services of the Site
Login credentials Account Management Contractual necessity and the provision of the services of the Site
Your first and last name User identification Execution of the contract with you and the provision of the services of the Site
Your phone number User identification, information mailing This data is optional and can be used by us just for providing you the services
Payment Data Financial record keeping Legal and contractual compliance
Your time zone Scheduling sessions This data is optional and can be used by us just for providing you the services
Photos, audio/video Learning support and user identification This data is not mandatory and can be provided by you optionally and can
Technical information For our understanding how the users use our Site, to improve the Site, to develop new (additional) services This data is optional and can be used by us just for providing you the services
Data about your usage of the site Site optimisation This data is optional and can be used by us just for providing you the services
HOW WE USE INFORMATION
We may use your personal information to:
provide you with and personalise our products and services;
create and manage your account, process your orders, and provide you customer service;
maintain our internal records, comply with legal requirements, and otherwise manage our business;
send you newsletters and advertisements and otherwise correspond with you about products, services, events, and other organisations that we think may interest you or, if an organisational customer arranged for your participation in our programs, send you newsletters and otherwise correspond with you about our products, services, and events that we think may interest you;
ask for your reviews and testimonials and send you surveys and questionnaires;
include as content in our products and services and marketing materials if you have provided permission;
administer sweepstakes and other promotions;
develop and display content and advertising tailored to your interests on our Site and other sites, provide our advertisements to you when you visit other sites, and analyse the effectiveness of our advertisements or, if an organizational customer arranged for your participation in our programs, develop and display content tailored to your interests on our Site;
perform research and analysis about your use of or interest in our services and our Site;
utilise excerpts of recorded online class sessions for advertisement purposes;
detect, prevent, or investigate illegal activity or misuse of our products or services and enforce our legal rights; and
perform functions as otherwise described to you at the time of collection.
DATA RETENTION
We retain personal data for as long as necessary to fulfil the purposes outlined in this Policy or as required by law. Upon account deletion, all data will be irretrievably deleted, subject to any legal obligations for retention.
DATA SHARING AND TRANSFER
Your data may be shared with eTutors staff, bound by confidentiality, contractors and service providers strictly on a need-to-know basis, business consultants, lawyers, and auditors; government bodies upon lawful request; prospective investors, subject to data protection safeguards. We do not sell personal data or use it for third-party marketing.
Service Providers and Other Vendors
We may disclose your personal information to our service providers and other vendors, such as those who provide tools for communicating and exchanging information with customers, help us manage our relationships with customers, process transactions (including providing payment options), license content to us, provide instruction, produce and deliver materials to customers, help us market our products and services, provide tools for online forms and surveys, analyse online activity, provide online hosting and storage services, and otherwise help deliver our products and services and operate our business.
Legally Compelled Disclosures and Safety
We may disclose personal information when compelled to do so by government authorities or otherwise as required or permitted by law, such as to respond to court orders and subpoenas. We may also disclose personal information to protect the safety of others and when we have reason to believe that someone is causing injury to or interfering with our rights or property or the rights or property of others.
Business Transfer
If we or all or a portion of our business is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, personal information may be included in the transferred assets.
Authorized Disclosure
We may disclose your personal information to third parties when you authorize the disclosure.
Non-Personal Information
We may disclose non-personal Information to any third party for any lawful purpose.
Your Access to Information
If you have an account with us, you may review and correct the information that is accessible to you under the settings for your account on our Site.
Opting Out of Promotional Correspondence
You may elect not to receive promotional correspondence from us. If you have an account with us, you may make this request under the settings for your account by indicating which correspondence you would like to receive.
Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
Using Caution when Sharing Information with Others
When you contribute to a public area or feature of our Site, such as a chat room, bulletin board, list serve, blog, or wiki, the information that you submit will be made available to the general public.
Therefore, we recommend that you do not submit any sensitive information to such areas of our Site, including your full name, home address, phone number, financial information or any other information that would enable other users to locate you or contact you.
SECURITY AND BREACH NOTIFICATIONS
While we employ commercially reasonable measures to secure your data, no system is completely immune to breaches. In the event of a data breach, we shall notify affected individuals within 72 hours; provide information on the nature of the breach and mitigation steps; and cooperate with authorities as required.
USERS OUTSIDE OF NIGERIA
By providing personal information to this Site, you understand and consent to the collection, maintenance, processing and transfer of such information in and to Nigeria and other countries and territories, in accordance with applicable law. The processing by us of the personal information of individuals outside of Nigeria is generally incidental. We do, however, recognize the privacy-related rights of individuals in countries which provide such rights, and therefore, request that any such individuals who have questions about or requests related to the personal information we collect to contact us.
USER-GENERATED CONTENTS
Information shared in public forums (e.g. chats, blogs, bulletin boards) becomes publicly available. We strongly advise against posting sensitive personal data in such areas.
AMENDMENTS
This Policy may be updated periodically. The latest version will always be posted on our website with the corresponding “Effective Date”. Continued use of the Site after changes implies acceptance of the updated terms.
CONTACT US
If you have any questions or comments regarding this Privacy Policy or our privacy practices, you may contact us by email: [email protected]