Your use of our services and any dispute over privacy is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this Policy.
3. Information We Collect.
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.
3.1. 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.
3.2. 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:
3.2.1. – Contact information;
3.2.2. – Identification information;
3.2.3. – Any other information you provide to us.
4. Using Your Personally Identifiable Information
“Personally Identifiable Information” means any information that (a) identifies or can be used to identify, contact, or locate the person to whom such information pertains, or (b) from which identification or contact information of an individual person can be derived.
We primarily collect your information to ensure that we provide the most efficient 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:
4.1. To help us verify your identity;
4.2. To carry out our obligations ensuing from any contracts entered into between you and us;
4.3. To provide you with the products, services, and information you request from us;
4.4. To assist you with inquiries and improve our customer service;
4.5. To assist us in carrying out marketing analysis and customer profiling, conduct research, including creating statistical and testing information;
4.6. To allow us to communicate with you in any way (including e-mail, telephone, visit, and text or multimedia messages);
4.7. For our billing and account purposes;
4.8. To help prevent and detect cyber activity;
4.9. To update our records;
4.10. To make recommendations and suggestions to you about services offered by us unless you have previously asked us not to do so;
4.11. To send you service or support messages, such as updates, security alerts, email notifications, and /or newsletters;
4.12. For compliance with legal and regulatory obligations.
5. Data Accuracy
Your personal data must be accurate and kept up to date. In this regard, Imperial EdTech 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.
6. Other Information We Collect
Other information that may be automatically collected from you when you visit our website include; the 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.
7. Data Confidentiality
Your information is regarded as confidential and can be shared with a third party in regards to whatever purpose you consent to and would also be shared 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 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 on our platform, adherence with physical security protocols on our premises, and dealing with only authorized officers of Imperial EdTech.
Keeping your information accurate and up to date is very important. If your information is incomplete, inaccurate, or not current, please use the Contact Us option on our Site, or call or write to us at the telephone numbers or appropriate address for changes. You can also speak to a customer representative from the Company.
8.2. We may request and provide information about you from and to third parties to provide our services.
8.3. We will notify you as soon as we become aware of a harmful data breach that may result in a risk of your rights and freedom.
8.4. You have the right to request an erasure of your data at any time.
8.5. We will notify you if we are transferring your data.
8.6. You may request at any time that we halt further dissemination of your data or cease to use your data.
8.7. 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.
8.8. 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.
8.9. 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.
9.0. Transfer of Personal Data
9.1. Third-Party Processor within Nigeria.
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 Imperial EdTech 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 Nigeria Data Protection Regulation (NDPR).
9.2. Transfer of Personal Data to Foreign Country
9.2.1. Where your personal data is to be transferred to a country outside Nigeria, Imperial EdTech shall put adequate measures in place to ensure the security of such data. In particular, Imperial EdTech 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.
9.2.2. Add assessment of whether the said country is on the National Information Technology Development Agency (NITDA) White List of Countries with adequate data protection laws.
9.2.3. Transfer of your personal data out of Nigeria would be in accordance with the provisions of the NDPR. Imperial EdTech will therefore only transfer your personal data out of Nigeria on one of the following conditions:
Your explicit consent has been obtained;
The transfer is necessary for the performance of a contract between you and Imperial EdTech
The transfer is necessary to conclude a contract between Imperial EdTech and a third party in your interest;
The transfer is necessary for reasons of public interest;
The transfer is for the establishment, exercise or defense of legal claims;
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.
9.3. 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.
9.4. 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.
9.5. Where the recipient country is not on the White List and none of the conditions stipulated in clause 9.2.2 of this policy is met, Imperial EdTech will engage with NITDA and the Office of the Honourable Attorney General of the Federation (HAGF) for approval with respect to such transfer.
10. Your Rights
Subject to certain limitations and exceptions, you are entitled to the following principal rights under the NDPR:
10.1. You have the right to be notified if we are transferring your personal information.
10.2. You have the right to request an erasure of your personal information at any time.
10.3. You have the right to request that we rectify inaccurate personal information.
10.4. You may request at any time that we halt further dissemination of your data or cease to use your personal information.
10.5. You have the right to request for copies of your personal information.
11. Website Security
We are committed to ensuring that your information is secure. In order to prevent unauthorized 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.
We 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 NDPR 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 NDPR
14. The Data We Retain
We 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.
15. Data Breach Management Procedure
15.1. 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:
15.1.1. notify you within 24 hours of the occurrence of the data breach;
15.1.2. properly investigate the breach and take the necessary steps to mitigate such breach;
15.1.3. identify remediation requirements and track the resolution of such breach; and
15.1.4. notify NITDA or any other regulatory authority, where necessary.
16. Links to Other Websites
16.1. Our website contains links to other websites and services that are owned or controlled by us.
16.2. We have control over and assume responsibility for, the content, privacy policies, or practices of these websites or services.
16.3. We strongly advise you to read the terms and conditions and privacy policies of these websites or services that you visit.
17. Limitation of Liability
We exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, we will not be liable for unauthorized disclosure of personal data that occurs through no fault of ours.
19. Contact Us