Privacy Policy

Last updated: May 21, 2026  —  Version 2.0

This Privacy Policy describes the policies and procedures of eduCentral on the collection, use, storage, sharing, and disclosure of Your information when You use the Service. It also tells You about Your privacy rights and how Nigerian law and applicable international regulations protect You.

We are committed to protecting the personal data of all users of the eduCentral platform — including educators, administrators, institutions, associations, vendors, regulators, and all key stakeholders in the educational sector — in full compliance with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation 2019 (NDPR), and where applicable, the General Data Protection Regulation (GDPR) and other relevant international standards.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. This includes educators, administrators, school staff, institution representatives, association officials, vendors, regulators, and any other stakeholder in the education sector.

    Under the NDPA 2023 and GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) — eduCentral, operated from Lagos, Nigeria.

    For the purpose of the NDPA 2023 and GDPR, the Company is the Data Controller.

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Account means a unique account created for You to access our Service or parts of our Service.
  • Website refers to eduCentral, accessible from https://edu-central.org/
  • Service refers to the Website and all sub-applications accessible at https://edu-central.org and its sub-domains.
  • Country refers to: Lagos, Nigeria

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

    For the purpose of the NDPA 2023 and GDPR, Service Providers are considered Data Processors and are required to enter into a Data Processing Agreement (DPA) with the Company before being granted access to any Personal Data.

  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Facebook Fan Page is a public profile named eduCentral specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/educentralng/

  • Personal Data is any information that relates to an identified or identifiable individual.

    For the purposes of the NDPA 2023 and GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

    Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

  • Sensitive Personal Data means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, or financial information. Such data is processed only with explicit consent or where required by law.
  • Multi-Factor Authentication (MFA) means a security mechanism requiring users to provide two or more verification factors to gain access to the Service.
  • NDPA means the Nigeria Data Protection Act 2023.
  • NDPR means the Nigeria Data Protection Regulation 2019, issued by the National Information Technology Development Agency (NITDA).
  • NDPC means the Nigeria Data Protection Commission, the supervisory authority for data protection in Nigeria.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Data Controller, for the purposes of the NDPA 2023 and GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Full name and title
  • Email address
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Date of birth (for identity verification purposes)
  • National Identification Number (NIN), Passport, or other government-issued ID
  • Bank account information in order to pay for products and/or services within the Service
  • Professional credentials and institutional affiliations
  • Role and designation within an educational institution or association
  • Usage Data

Stakeholder-Specific Data

In line with our mission to serve all key players in the educational sector, We may collect additional information based on Your role on the platform:

  • Educators / Teachers: Teaching qualifications, subject specialisation, employment records, professional registration numbers.
  • Administrators / School Staff: Administrative role, institution name, staff ID.
  • Institutions: School or institution name, registration number, accreditation status, contact person details.
  • Associations: Association name, registration details, membership lists (with consent), key officials.
  • Vendors / Service Providers: Business name, CAC registration number, tax identification, product or service descriptions, contact details.
  • Regulators: Agency name, official designation, mandate scope, authorisation credentials.

When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:

  • Date of birth
  • Passport or National ID card
  • Bank card statement
  • Other information linking You to an address

Data Accuracy and Regular Updates

In accordance with the NDPA 2023, We are committed to keeping Your personal data accurate, complete, and up to date. You are required to promptly notify Us of any changes to Your personal information. You may update Your data at any time through Your account settings or by contacting Us directly. We conduct periodic data accuracy reviews and may contact You to verify or update Your records. We also perform annual data retention reviews to ensure that data is not held longer than necessary.

Account Activity and Suspension

Accounts that are not updated within thirty (30) days may be automatically discarded from our system. User accounts that remain inactive and are not logged into for a continuous period of one hundred and eighty (180) days will be automatically suspended. Additionally, schools whose operations remain inactive for one hundred and eighty (180) days may be suspended and may be subject to a reversion to an annual subscription plan at our discretion.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

  • Google
  • Facebook
  • Twitter

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. Learn more about cookies: All About Cookies.

We use both session and persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

    Type: Session Cookies

    Administered by: Us

    Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

  • Cookies Policy / Notice Acceptance Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

  • Functionality Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

  • Security (MFA) Cookies

    Type: Session / Short-lived Persistent Cookies

    Administered by: Us

    Purpose: These Cookies support Multi-Factor Authentication verification processes and trusted device recognition to protect Your account from unauthorised access.

  • Tracking and Performance Cookies

    Type: Persistent Cookies

    Administered by: Third-Parties

    Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • To facilitate collaboration between educators, administrators, institutions, associations, vendors, regulators, and other educational stakeholders on the platform for the effective development and growth of education.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To verify Your identity in compliance with Know Your Customer (KYC) requirements and applicable Nigerian regulations.
  • To enforce Multi-Factor Authentication (MFA) and other security measures to protect Your account and Personal Data.
  • To comply with legal obligations under Nigerian law and applicable international laws, including the NDPA 2023 and NDPR 2019.
  • To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to advertise on third party websites to You after You visited our Service, for payment processing, to contact You, and to support the delivery of MFA and security services. All Service Providers are required to enter into a Data Processing Agreement (DPA) with the Company before accessing any Personal Data.
  • For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • Within the Educational Ecosystem: When You interact with other users on the platform — such as joining an institution, participating in an association, or engaging with a vendor — certain profile information may be shared within the platform to facilitate collaboration. Educators' verified credentials may be shared with institutions that engage them, subject to consent. Institution data may be shared with relevant regulators for compliance purposes. Regulators may access aggregated, anonymised data as required by their official mandate.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Specific retention periods apply as follows:

  • Account data is retained for the duration of Your account and for 5 years after account closure, in accordance with applicable Nigerian legal and regulatory requirements.
  • Transaction records are retained for a minimum of 6 years in compliance with Nigerian tax and financial regulations.
  • Usage Data and logs are generally retained for 30 days, unless required for security investigations or legal obligations.
  • MFA authentication logs are retained for 30 days for security audit purposes.
  • Marketing preferences are retained until You withdraw Your consent or object to processing.

We conduct annual data retention reviews to ensure that data is not held longer than necessary. The Company will also retain Usage Data for internal analysis purposes, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is primarily processed and stored in Nigeria. Where data is transferred to or accessed from outside Nigeria, the Company ensures adequate safeguards are in place, including transfers to countries recognised by the NDPC as providing an adequate level of data protection, and the use of Standard Contractual Clauses (SCCs) or equivalent binding instruments approved under the NDPA 2023.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court, the NDPC, NITDA, the Ministry of Education, or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is a top priority for Us. We implement and maintain a comprehensive, risk-based security programme in accordance with the NDPA 2023, NDPR 2019, and international best practices.

Technical Security Measures

  • Encryption in Transit: All data transmitted between Your device and our servers is encrypted using TLS 1.2 or higher (HTTPS).
  • Encryption at Rest: Sensitive stored data, including passwords (hashed) and payment information, is encrypted at rest.
  • Multi-Factor Authentication (MFA): MFA is enforced for all privileged and sensitive account actions as described in the MFA section below.
  • Access Controls: We enforce role-based access controls (RBAC) ensuring staff and systems can only access data necessary for their specific function (principle of least privilege).
  • Audit Logging: All access to Personal Data and system events are logged and subject to regular review to detect unauthorised activity.
  • Intrusion Detection and Prevention: Our infrastructure is monitored continuously with automated intrusion detection and prevention systems (IDS/IPS).
  • Vulnerability Management: We conduct regular vulnerability assessments and penetration testing to identify and remediate security weaknesses.
  • Data Backups: Regular encrypted backups are maintained to ensure data availability and resilience against data loss.

Organisational Security Measures

  • All staff with access to Personal Data are bound by strict confidentiality agreements and receive regular data protection training.
  • Access to Personal Data is granted on a need-to-know basis and reviewed periodically.
  • Third-party vendors and service providers undergo security vetting and are bound by Data Processing Agreements (DPAs) that enforce equivalent security standards.
  • We maintain an Incident Response Plan to address data breaches swiftly and in compliance with the NDPA 2023 mandatory breach notification requirements.

Data Breach Notification

In the event of a personal data breach likely to result in a risk to Your rights and freedoms, We will notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach, in accordance with the NDPA 2023. We will also notify affected users without undue delay with information on the nature of the breach, data affected, and steps taken to mitigate harm.

While We strive to use commercially acceptable means to protect Your Personal Data, no method of transmission over the Internet, or method of electronic storage is 100% secure. We cannot guarantee its absolute security but commit to ongoing improvement of our security measures.

Multi-Factor Authentication (MFA)

To enhance the security of user accounts and protect sensitive educational and personal data, eduCentral has implemented Multi-Factor Authentication (MFA) across the platform.

What is MFA?

MFA is a security process that requires You to provide two or more verification factors to access Your account. This significantly reduces the risk of unauthorised access even if Your password is compromised.

MFA Methods Available

The following MFA methods are supported on eduCentral:

  • One-Time Password (OTP) via SMS — A time-sensitive code sent to Your registered phone number.
  • One-Time Password (OTP) via Email — A time-sensitive code sent to Your registered email address.
  • Authenticator App — Support for TOTP-based authenticator applications (e.g., Google Authenticator, Microsoft Authenticator, Authy).

Data Processed for MFA

To deliver MFA, we process the following data solely for security and fraud prevention purposes:

  • Your registered phone number (for SMS-based OTP)
  • Your registered email address (for email-based OTP)
  • Timestamps of authentication attempts
  • Device identifiers (to detect and alert on new device logins)
  • Login location (IP address and approximate geography, for anomaly detection)

MFA data is not used for any other purpose and is retained only as long as necessary to support Your account security. Authentication logs are retained for 90 days for security audit purposes.

MFA Requirement

MFA is mandatory for all users accessing sensitive features of the platform, including institutional administration, financial transactions, and regulatory data management. Users who do not complete MFA setup will have restricted access to protected areas of the Service.

Account Recovery

If You lose access to Your MFA device or method, You may initiate an account recovery process by contacting our support team at [email protected] with valid identity verification documents, in accordance with our Account Recovery Policy.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

  • Google Analytics

    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

    You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

    For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

  • Mailchimp

    Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

    For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

Behavioral Remarketing

The Company uses remarketing services to advertise on third party websites to You after You visited our Service. We and Our third-party vendors use cookies to inform, optimize and serve ads based on Your past visits to our Service.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service.

  • Invisible reCAPTCHA

    We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.

    The reCAPTCHA service may collect information from You and from Your Device for security purposes.

    The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

NDPA 2023 & NDPR 2019 Privacy (Nigerian Users)

Legal Basis for Processing Personal Data under Nigerian Law

In accordance with the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation 2019 (NDPR), We may process Personal Data under the following conditions:

  • Consent: You have given clear, informed, and freely given consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject under Nigerian or applicable international law.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company, where such interests are not overridden by Your rights and freedoms.

Your Rights under the NDPA 2023 and NDPR 2019

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the following rights under Nigerian data protection law:

  • The right to be informed. You have the right to be told what Personal Data We collect, why We collect it, and how it is used. This Privacy Policy fulfils that obligation.
  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation which makes You want to object. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data at any time. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
  • The right to lodge a complaint. You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at https://ndpc.gov.ng if You believe Your rights have been violated.

Exercising of Your NDPA Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You within 30 days. This period may be extended by a further 30 days in complex cases, with prior notice.

GDPR Privacy (EU/EEA Users)

Legal Basis for Processing Personal Data under GDPR

If You are located in the European Economic Area (EEA), We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Privacy

Your Rights

Under this Privacy Policy, and by law if You are a resident, You have the following rights:

  • The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to access / the right to request. The law permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
  • The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our "Do Not Sell My Personal Information" section or web page.

  • The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:

    • The categories of Personal Data collected
    • The sources from which the Personal Data was collected
    • The business or commercial purpose for collecting or selling the Personal Data
    • Categories of third parties with whom We share Personal Data
    • The specific pieces of Personal Data we collected about You
  • The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.

  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:

    • Denying goods or services to You
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to You
    • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your Data Protection Rights

In order to exercise any of Your rights under the law, and if you are a resident, You can email or call us or visit our Website to contact us.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the law.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

  • From Our "Cookie Consent" notice banner
  • Or from Our "Opt-out" notice banner
  • Or from Our "Do Not Sell My Personal Information" notice banner
  • Or from Our "Do Not Sell My Personal Information" link

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
  • "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.

"Do Not Track" Policy

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service at least 14 days before material changes take effect, and update the "Last updated" date at the top of this Privacy Policy. Where required by law, We will seek Your fresh consent before applying changes that affect how We process Your data.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

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