2. Definitions“consent” means the consent of the data subject which must be a freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they (by a statement or by a clear affirmative action) signify their agreement to the processing of personal data relating to them;“data controller” means the natural or legal person or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this policy, AltSchool is the data controller of all personal data relating to data subjects;“data processor” means a person or organisation which processes personal data on behalf of a data controller. This includes AltSchool, its employees and third-party service providers.“Data Protection Legislation” means all applicable data protection and privacy laws including, but not limited to the Nigeria Data Protection Regulation 2019 (NDPR) General Data Protection Regulation ((EU) 2016/679) (GDPR), the Data Protection Act 2018, the Privacy and any successor legislation;“Data Protection Officer” means an officer of AltSchool responsible for ensuring that all processing of personal data is in compliance with the Data Protection Legislation;“data subject” means any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that data subject;“personal data” means any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that data subject;“personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed;“processing” means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3. Data Protection Officer & Scope of Policy3.1. AltSchool’s Data Protection Office can be reached via [email protected]. The Data Protection Office is responsible for working together with the HR Department in administering this policy and for developing and implementing any applicable related policies, procedures, and guidelines.3.2. All managers, department heads and supervisors are responsible for ensuring that all employees, agents, contractors, or other parties working on behalf of AltSchool comply with this policy and, where applicable, must implement such practices, processes, controls, and training as are reasonably necessary to ensure such compliance.3.3. Any questions relating to this policy, AltSchool’s collection, processing, or holding of personal data, or to the Data Protection Legislation should be referred to the Data Protection Office.
4. Consent4.1. Where processing of your personal data is based on consent, we shall obtain the requisite consent at the time of collection of the personal information. In this regard, you consent to the processing of your personal information when you access our website, or use our services, content, features, technologies or functions offered on our website or other digital platforms. You can withdraw your consent at any time but such withdrawal will not affect the lawfulness of the processing of your data based on consent given before its withdrawal.4.2. Where your personal data is to be processed for a different purpose that is incompatible with the purpose or purposes for which that personal data was originally collected that was not disclosed to you when you first provided your consent, we will obtain your consent to the new purpose or purposes.
5. Age Restriction5.1. You affirm that you are over 18 years old and have the right to contract in your own name, and that you have read the above authorisation and fully understand its contents.5.2. Individuals under 18 years old are only allowed to sign up for our services or provide us with their information when an adult above the age of 18 is signing contracts in their stead.
6. Data Protection PrinciplesThe Data Protection Legislation sets out the following principles with which anyone handling personal data must comply. We, our employees, agents, contractors and third-party service providers comply with the following principles when collecting or processing your personal data. All personal data must be:6.1.processed lawfully, fairly, and in a transparent manner in relation to the data subject;6.2. collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;6.3. adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;6.4. accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay;6.5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection Legislation in order to safeguard the rights and freedoms of the data subject;6.6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
7. Information We Collect.In providing our educational services to you, we collect certain non-personal and personal data about you. Our policy is to keep this information confidential and strictly safeguarded, and to use or disclose it only as needed to provide services to you, or as permitted or required by the Data Protection Legislation.There are two categories of information we collect. We collect a variety of information from our users and visitors to our website. As described below, some information is automatically collected when you visit our website, and some you provide to us when filling out a form or communicating with us.7.1. Information Collected Automatically: Whenever you visit our website, our web servers automatically collect non-personal information such as the domain name of the internet access provider, the internet protocol address used to connect the computer to the internet, the average time spent on our website, pages viewed, information searched for, access times, and other relevant statistics.7.2. Information You Provide Us: If you provide us with personal information, by contacting us, or subscribing to our services we collect the following personal information:7.1.1. Username and password;7.1.2. Contact information;7.1.3. Educational information (e.g., academic history, CV, employment status etc.);7.1.4. Financial information where you make any payment for our services; and7.1.5. Any other information you provide to us.
8. Using Your Personal Data8.1. We primarily collect your personal data to ensure that we provide the most efficient educational service to you, monitor the use and improve our website and other legitimate interests. Your information will solely be used and disclosed for the following purposes:8.1.1 To help us verify your identity;8.1.2 To carry out our obligations ensuing from any contracts entered into between you and us;8.1.3 To provide you with the products, services and information you request from us;8.1.4 To assist you with enquiries and improve our customer service;8.1.5 To assist us in carrying out marketing analysis and customer profiling (including transactional information), conduct research, including creating statistical and testing information;8.1.6 To allow us to communicate with you in any way (including e-mail, telephone, visit, and text or multimedia messages);8.1.7 For our billing and account purposes;8.1.8 To help prevent and detect fraud or loss;8.1.9 To update our records;8.1.10 To make recommendations and suggestions to you about services offered by us unless you have previously asked us not to do so;8.1.11 To send you service or support messages, such as updates, security alerts, email notifications and /or newsletters;8.1.12 To conduct investigations and risk assessments; and8.1.13 For compliance with legal and regulatory obligations.8.2. Employees, agents, contractors, or other parties working on behalf of AltSchool shall collect your personal data only to the extent required for the performance of their job duties and only in accordance with this policy. Excessive personal data must not be collected.8.3. Employees, agents, contractors, or other parties working on behalf of AltSchool shall process your personal data only when the performance of their job duties requires it. Your personal data held by AltSchool cannot be processed for any unrelated reasons.
9. Data AccuracyYour personal data must be accurate and kept up to date. In this regard, AltSchool shall ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to you; make efforts to keep your personal data updated where reasonable and applicable; and make timely efforts to correct or erase your personal data when inaccuracies are discovered.
10. Data RetentionAltSchool shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed. In the case of your educational data, the purpose for which the data was collected is to provide you with our educational services which will equip you with technical skills needed for the careers of the future. Unless AltSchool receives a valid request to erase your educational data, the data is retained permanently. This allows your record of participation and progress in our educational program to be maintained. If the data were deleted, we would have no record of your performance and completion of our educational program.
11. Other Information We CollectOther information which may be automatically collected from you when you visit our website include; domain name of your internet service provider, the internet protocol address used to connect the computer to the internet, the average time spent on our website, pages viewed, information searched for, access times, your geographical location, operating system, referral source, and other relevant statistics. We may also collect information from you using cookies and other analytical tools especially when you use our products and services. More details are provided below in our section on Cookies.
12. Data ConfidentialityYour information is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions. You have the right to request copies of any and all information we keep on you, if such requests are made in compliance with applicable laws and other relevant enactments. While we are responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our premises, dealing with only authorized officers of AltSchool.
13. Disclosures13.1. We will not sell, publish, or disclose to third parties your personal data collected on our website, through our servers or otherwise obtained by us, other than to provide our services and as set forth in this policy. We may share generic aggregated demographic information not linked to any personally identifiable information regarding visitors and users with our business partners, trusted affiliates, professional advisers and advertisers for the purposes outlined above. We may share your information with these third parties for those limited purposes if you have given us your permission and in compliance with the Data Protection Legislation.13.2. We may request and provide information about you from and to third parties to provide our services.13.3. We will notify you as soon as we become aware of a harmful data breach which may result in a risk of your rights and freedom.13.4. You have the right to request an erasure of your data at any time.13.5. We will notify you if we are transferring your data.13.6. You may request at any time that we halt further dissemination of your data or cease to use your data.13.7. If you submit content in a public forum or a social media post, or use a similar feature on our website, that content is publicly visible.13.8. We may disclose Personally Identifiable Information if required to do so by law or in the good faith belief that such action is necessary to (a) conform with the requirements of the law or comply with legal process served on us, or (b) act in urgent circumstances to protect the personal safety of users of our service or members of the public.13.9. To the extent practicable and legally permitted, we will attempt to advise you prior to any such disclosure, so that you may seek a protective order or other relief limiting such disclosure.
14. Transfer of Personal Data14.1. Third Party Processor
We may engage the services of third parties in order to process your personal data. The processing by such third parties shall be governed by a written contract with AltSchool to ensure adequate protection and security measures are put in place by the third party for the protection of your personal data in accordance with the terms of this policy and the Data Protection Regulation.14.2. International Transfers
We have offices and facilities in Nigeria, [Insert other office locations]. To operate our business and provide you with our services, we may send your personal information to our other offices and outside of your country. Your personal information may be subject to the laws of the countries where we send it. When we send your information outside of your country of origin or residence, we shall ensure your personal information is protected, and only send your information to countries that have strong data protection laws.14.3. Transfer of Personal Data of UK Citizens and Citizens of an EU Country to Foreign Country
14.3.1 Where your personal data is to be transferred to a country outside the United Kingdom (UK) or the EU, AltSchool shall put adequate measures in place to ensure the security of such data. In particular, AltSchool shall, among other things, conduct a detailed assessment of whether there are issued regulations confirming that country in question ensures adequate level of protection.14.3.2 Transfer of your personal data to a country outside the UK or the EU would be in accordance with the provisions of the GDPR. AltSchool will therefore only transfer your personal data out of the UK or the EU on one of the following conditions:a. Your explicit consent has been obtained;b. The transfer is necessary for the performance of a contract between you and AltSchool;c. The transfer is necessary to conclude a contract between AltSchool and a third party in your interest;d. The transfer is necessary for reason of public interest;e. The transfer is for the establishment, exercise or defense of legal claims;f. The transfer is necessary in order to protect your vital interests or the interests of other persons, where you are physically or legally incapable of giving consent.14.3.3 Provided, in all circumstances, that you have been manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country, this provision shall not apply to any instance where you are answerable in duly established legal action for any civil or criminal claim in another country.14.3.4 We will take all necessary steps to ensure that your personal data is transmitted in a safe and secure manner. Details of the protection given to your information when it is transferred outside the UK or the EU shall be provided to you upon request.14.3.5 Where the recipient country does not ensure adequate an adequate level of protection and none of the conditions stipulated in clause 14.3.2 of this policy is met, AltSchool will engage with the Information Commissioner’s Office for approval with respect to such transfer.
14.4. Transfer of Personal Data of Nigerian Citizens to a Foreign Country14.4.1 Where your personal data is to be transferred to a country outside Nigeria, we shall put adequate measures in place to ensure the security of such data. In particular, we shall, among other things, conduct a detailed assessment of whether the said country is on the National Information Technology Development Agency (NITDA) White List of Countries with adequate data protection laws.14.4.2 Transfer of your personal data out of Nigeria would be in accordance with the provisions of the NDPR. We will therefore only transfer your personal data out of Nigeria on one of the following conditions:a. Your explicit consent has been obtained;b. The transfer is necessary for the performance of a contract between you and AltSchool;c. The transfer is necessary to conclude a contract between AltSchool and a third party in your interest;d. The transfer is necessary for reason of public interest;e. The transfer is for the establishment, exercise or defense of legal claims;f. The transfer is necessary in order to protect your vital interests or the interests of other persons, where the you are physically or legally incapable of giving consent.14.4.3. Provided, in all circumstances, that you have been manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country, this provision shall not apply to any instance where you are answerable in duly established legal action for any civil or criminal claim in another country.14.4.4. We will take all necessary steps to ensure that your personal data is transmitted in a safe and secure manner. Details of the protection given to your information when it is transferred outside Nigeria shall be provided to you upon request.14.4.5. Where the recipient country is not on the White List and none of the conditions stipulated in clause 14.4.2 of this policy is met, AltSchool will engage with NITDA and the Office of the Honourable Attorney General of the Federation (HAGF) for approval with respect to such transfer.
15. Your RightsSubject to certain limitations and exceptions, you are entitled to the following principal rights under the Data Protection Legislation:15.1. You have the right to be notified if we are transferring your personal information.15.2. You have the right to request an erasure of your personal data at any time.15.3. You have the right to request that we rectify inaccurate personal information.15.4. You may request at any time that we halt further dissemination of your data or cease to use your personal information.15.5. You have the right to request for copies of your personal information.
16. Website SecurityWe are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as secure sockets layer (SSL) to safeguard and secure the information we collect online. We use encryption tools when accepting and transmitting delicate visitor information through our website. Some of the other safeguards we use are firewalls and physical access controls to our data centres, and information access authorization controls.
17. TrainingWe shall ensure that employees who collect, access and process your personal data receive adequate data privacy and protection training in order to develop the necessary knowledge, skills and competence required to effectively manage the compliance framework under this policy and the Data Protection Legislation with regard to the protection of personal data. On an annual basis, we shall develop a capacity building plan for our employees on data privacy and protection in accordance with the Data Protection Legislation.
19. The Data We RetainWe will retain your information for as long as needed to provide you with our services, comply with our legal and statutory obligations or verify your information with a financial institution. We are statutory obligated to retain the data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud and in compliance with laws and regulatory guidelines applicable to us.
20. Data Breach Management Procedure20.1. In the event where there is any accidental or unlawful destruction, processing, loss, alteration, unauthorized disclosure of, or access to your personal data, we shall:20.1.1. notify you within 24 hours of the occurrence of the data breach;20.1.2. properly investigate the breach and take the necessary steps to mitigate such breach;20.1.3. identify remediation requirements and track the resolution of such breach; and20.1.4. notify the Information Commissioner’s Office or any other regulatory authority, where necessary.
21. Links to Third Party Websites 21.1. Our website may contain links to third-party websites or services that are not owned or controlled by us. 21.2. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such websites or services. 21.3. We strongly advise you to read the terms and conditions and privacy policies of any third-party websites or services that you visit.
22. Limitation of Liability We exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, we will not be liable for unauthorised disclosure of personal data that occurs through no fault of ours.