Privacy Policy

At Skoolbod, our Data Subjects’ Personal Data privacy is extremely important to us. In line with our
the resolution, we have developed this Privacy Policy to explain your privacy rights regarding our gathering, use, sharing, and protect your Personal Data when you visit our website, work environment, or use our digital platforms.
This privacy policy between you and Skoolbod establishes our obligation to protect your privacy on all
platforms. It is designed to provide information regarding our privacy practices and help you understand
how we handle your data. By using the Skoolbod website and all applications, software, and services
(collectively, “Services”) available on the website, you consent to the data practices described in this
Statement.

TABLE OF CONTENTS

1. Consent
2. What information do we collect?
3. How do we use your information?
4. How do we Retain Personal Data?
5. Will your information be shared with a third party?
6. External Links
7. Sharing Information with Third Parties
8. Tracking User Behaviour
9. Automatically Collected Information
10. Use of Cookies
11. Security of your Personal Information
12. Children’s Privacy
13. What Are Your Rights?
14. Email Communications
15. External Data Storage Sites
16. Remedies for Violation and Timeframe for Remedy
17. Governing Law
18. Changes to this Statement
19. Contact Information
20. Consent
    You accept this privacy policy when you give consent upon access to our platforms, use the services offered
    on our website and digital platform or visit any of our offices for official or non-official purposes.
21. What information do we collect?
    We collect Personal Data about you when you use the services offered on our website and digital platform,
    including the following:
    2.1 Sign-up information: In order to better provide you with products and services offered, when you
    register to use the services offered on our digital platform Skoolbod may collect personally
    identifiable information that is necessary to on-board you, such as your:

• First and Last Name
• Mailing Address
• Email Address
• Phone Number
• Any other additional personal details are necessary to use our services.
  2.2 Information from other sources: We may collect information from other sources, such as our social
  media platforms, when you reach out to us to lodge a complaint about our services. However, we
  will only ask for the information required to help us be of service to you.
  2.3 Demographic Information: Skoolbod may also collect anonymous demographic information,
  which is not unique to you, such as your:
• Age
• Gender
  2.4 Payments: We may provide paid services and/or offer a payment channel through the solution. In
  that case, we use third-party services for payment processing (e.g. payment processors). That
  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. PCI-DSS requirements help
  ensure the secure handling of Payment information. The payment processors we work with is;
  • Paystack
  2.5 Educational Content Data: When you access content on Skoolbod, we collect certain data including
  which courses, assignments, labs, workspaces, and quizzes you’ve started and completed; content
  purchases and credits; subscriptions; completion certificates; your exchanges with instructors,
  teaching assistants, and other students; and essays, answers to questions, and other items submitted
  to satisfy course and related content requirements. If you are an instructor, we store your educational
  content which may contain data about you.
  2.6 Sweepstakes, Promotions, and Surveys: We may invite you to complete a survey or participate in
  a promotion (like a contest, sweepstakes, or challenge), either through the Services or a third-party
  platform. If you participate, we will collect and store the data you provide as part of participating,
  such as your name, email address, postal address, date of birth, or phone number. That data is subject
  to this Privacy Policy unless otherwise stated in the official rules of the promotion or in another
  privacy policy. The data collected will be used to administer the promotion or survey, including for
  notifying winners and distributing rewards. To receive a reward, you may be required to allow us to
  post some of your information publicly (like on a winner’s page). Where we use a third-party
  platform to administer a survey or promotion, the third party’s privacy policy will apply.
  2.7 Third Party Sites: We may receive Personal Data when you access or log-in from a third party site,
  e.g., Facebook, from our Sites. This may include the text and/or images of your Personal Data
  available from the third party site.
  2.8 Partner sites: Partner sites providing Content Offering-related tools and services to Skoolbod users
  may collect nonfinancial individual-level user data regarding the individual’s use of that partner site
  while the partner sites provide those services to Skoolbod. The partner sites may share that data with
  Skoolbod for the purpose of improving our Services, the partner site’s services, and the individual’s
  education experience. This data includes information such as the amount of time spent on the partner
  site and pages viewed.
  2.9 Other information we collect related to your use of our website or Services: We may collect
  additional information from or about you when you communicate with us, contact our customer
  support teams, or respond to a survey.
  We do not collect any personal information about you unless you voluntarily provide it to us. However,
  you may be required to provide certain personal information to us when you elect to use certain products
  or services.
  These may include but not limited to:
  (a) registering for an account.
  (b) entering sweepstakes or contests sponsored by one of our partners or us.
  (c) signing up for special offers from selected third parties and.
  (d) sending us an email message.
  To wit, we will use your information for, but not limited to, communicating with you in relation to services
  and/or products you have requested from us. We also may gather additional personal or non-personal
  information in the future.

1. How do we use your information?
   Skoolbod collects and uses your personal information to operate and deliver your requested services.
   Skoolbod may also use your personally identifiable information to inform you of other products or services
   available from Skoolbod and its affiliates.
   We use the data we collect through your use of the Services to:
   i. Provide and administer the Services, including, facilitating participation in educational content,
   issuing completion certificates, display customized content, and facilitate communication with
   other users.
   ii. Process payments to instructors and other third parties.
   iii. Process your requests and orders for educational content, products, specific services, information,
   or features.
   iv. Communicate with you about your account by:
   • Responding to your questions and concerns.
   • Sending you administrative messages and information, including messages from instructors,
   students, and teaching assistants; notifications about changes to our Service; and updates to our
   agreements.
   • Sending you information, such as by email or text messages, about your progress in courses and
   related content, rewards programs, new services, new features, promotions, newsletters, and
   other available instructor-created content (which you can opt out of at any time);
   v. Manage your account and account preferences and personalize your experience.
   vi. Facilitate the Services’ technical functioning, including troubleshooting and resolving issues,
   securing the Services, and preventing fraud and abuse.
   vii. Verify the identity of instructors.
   viii. Solicit feedback from users.
   ix. Market products, services, surveys, and promotions.
   x. Market Subscription Plans to prospective customers.
   xi. Learn more about you by linking your data with additional data through third-party data providers
   or
   xii. As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity
   of our users, employees, third parties, the public, or our Services.
2. How Do We Retain Personal Data?
   We retain Personal Data in an identifiable format for at least seven (7) days for our business purposes and
   to fulfil our legal or regulatory obligations. We may retain Personal Data for longer periods if it is in our
   legitimate business interests and required to comply with applicable laws. We will continue to use and
   disclose such Personal Data in accordance with this Privacy Policy.
3. Who We Share Your Data With?
   We may share your data with third parties under the following circumstances or as otherwise described in
   this Privacy Policy:
   5.1 With Your Instructors: We share data that we have about you (except your email address) with
   instructors or teaching assistants for educational content you access or request information about, so
   they can improve their content for you and other students.
   5.2 With Other Students and Instructors: Depending on your settings, your shared content and profile
   data may be publicly viewable, including to other students and instructors. If you ask a question to
   an instructor or teaching assistant, your information (including your name) may also be publicly
   viewable.
   5.3 With Service Providers, Contractors, and Agents: We share your data with third-party companies
   who perform services on our behalf, like payment processing, fraud and abuse prevention, data
   analysis, marketing and advertising services (including retargeted advertising), email and hosting
   services, and customer services and support. These service providers may access your personal data
   and are required to use it solely as we direct, to provide our requested service.
   5.4 With Business Partners: We have agreements with other websites and platforms to distribute our
   Services and to also provide us with resource materials, we may share your data with these partners.
   5.5 For Advertising: If we decide to use an advertising-supported revenue model in the future, we may
   use and share certain System Data and Usage Data with third-party advertisers and networks to show
   general demographic and preference information among our users.
   5.6 For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole
   discretion) have a good faith belief that the disclosure is:
   • Permitted or required by law.
   • Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding.
   • Reasonably necessary as part of a valid subpoena, warrant, or other legally valid request.
   • Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal
   agreements.
   • Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or
   rule or regulation), or security or technical issues; or
   • Reasonably necessary in our discretion to protect against imminent harm to the rights,
   property, or safety of Skoolbod, our users, employees, members of the public, or our
   Services.
   • We may also disclose data about you to our auditors and legal advisors in order to assess
   our disclosure obligations and rights under this Privacy Policy.
   5.7 During a Change in Control: If Skoolbod undergoes a business transaction like a merger,
   acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of
   its assets, we may share, disclose, or transfer all of your data to the successor organization during
   such transition or in contemplation of a transition (including during due diligence).
4. External Links
   For your convenience we may provide links to sites operated by organizations other than Skoolbod (“Third
   Party Sites”) that we believe may be of interest to you. We do not disclose your Personal Data to these
   Third-Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not
   responsible for the privacy practices of these Third-Party Sites. If you choose to click on a link to one of
   these Third-Party Sites, you should review the privacy policy posted on the other site to understand how
   that Third Party Site collects and uses your Personal Data, as Skoolbod is not responsible for contents,
   navigations and ads displayed on those sites.
5. Sharing Information with Third Parties
   Skoolbod does not sell, rent or lease its customer lists to third parties. Skoolbod may share data with trusted
   partners to help perform statistical analysis, send you email or postal mail, provide customer support, or
   arrange for deliveries. All such third parties are prohibited from using your personal information except to
   provide these services to Skoolbod, and they are required to maintain the confidentiality of your
   information.
   Skoolbod may disclose your personal information without notice, if required to do so by law or in the good
   faith belief that such action is necessary to:
   (a) conform to the edicts of the law or comply with legal process served on Skoolbod or the Site.
   (b) protect and defend the rights or property of Skoolbod; and/or
   (c) act under exigent circumstances to protect the personal safety of users of Skoolbod, or the public.
6. Tracking User Behavior
   Skoolbod may keep track of the websites and pages our users visit within Skoolbod to determine what
   Skoolbod services are the most popular. This data is used to deliver customized content and advertising
   within Skoolbod to customers whose behavior indicates that they are interested in a particular subject area.
7. Automatically Collected Information
   Skoolbod may automatically collect information about your computer hardware and software. This
   information can include your IP address, browser type, domain names, access times, and referring website
   addresses. This information is used for the operation of the service, to maintain quality of the service, and
   to provide general statistics regarding use of the Skoolbod website.
8. Use of Cookies
   The Skoolbod website may use “cookies” to help you personalize your online experience. A cookie is a text
   file placed on your hard disk by a web page server, and cookies cannot be used to run programs or deliver
   viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the
   domain that issued the cookie to you.
   One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose
   of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize
   Skoolbod pages or register with the Skoolbod site or services, a cookie helps Skoolbod recall your specific
   information on subsequent visits. This simplifies the process of recording your personal information, such
   as billing addresses, shipping addresses, and so on. When you return to the same Skoolbod website, the
   information you previously provided can be retrieved, so you can easily use the Skoolbod features that you
   customized.
   You can accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually
   modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not
   be able to fully experience the interactive features of the Skoolbod services or websites you visit.
9. Security of your Personal Information
   We maintain technical, physical, and administrative security measures designed to provide reasonable
   protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The
   security measures include firewalls, data encryption (such as the Secure Sockets Layer (SSL) protocol),
   physical access controls to our premises, CCTV cameras for public safety and quality control, and
   information access authorization controls. While we are dedicated to securing our systems and services,
   you are responsible for ensuring and maintaining the privacy of your password(s) and account/profile
   registration information and verifying that the Personal Data we maintain about you is accurate and current.
   We will inform you of any breaches which may affect your Personal Data. We strive to take appropriate
   security measures to protect against unauthorized access to or alteration of your personal information.
   Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100%
   secure. As a result, while we strive to protect your personal information, you acknowledge that:
   (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and
   (b) security, integrity, and privacy of any and all information and data exchanged between you and us
   through this Site cannot be guaranteed.
10. Children’s Privacy
    Skoolbod, as a School Management Website, is intended for students in the Early Years Foundation Stage
    and above, and we will not collect personal information from children under the age of 14 without
    parental/guardian consent. If this is not the case, such information will be removed from our website.
11. What Are Your Rights?
    13.1 Requests to Access, Rectify, or Erase.
    a. Access Request
    You have the right to ask us whether we hold any Personal Data relating to you and, if we do, to be
    provided with a copy of that Personal Data in electronic form, unless you want to receive it in another
    way (for example, a paper copy). In addition, you can ask us for information on how we use your
    Personal Data, who we share it with, how long we keep it, where it is stored, and other information to
    help you understand how we use it.
    b. Rectification Request
    You have the right to ask us to correct your Personal Data (including by means of providing a
    supplementary statement) if it is inaccurate and to have incomplete Personal Data updated without
    undue delay. If we cannot correct the Personal Data, we include a note on our files regarding your
    request to correct your Personal Data.
    c. Erasure Request
    You have the right to ask us to erase your Personal Data if:
    i. Your Personal Data is no longer necessary for the purpose(s) they were collected for.
    ii. Your Personal Data has been unlawfully processed.
    iii. Your Personal Data must be erased to comply with a regulation.
    iv. You withdraw your consent to process the Personal Data (and if this is the only basis on which
    we are processing your Personal Data).
    v. You object to processing that is based on our legitimate interests, provided there are no overriding
    legitimate grounds for continued processing, or
    vi. You object to processing for direct marketing purposes.
    Suppose we have made the Personal Data concerned public. In that case, we will also take reasonable steps
    to inform other data controllers processing the data so they can seek to erase links to or copies of your
    Personal Data. We may refuse to act on your request to erase your Personal Data if the processing of your
    Personal Data is necessary:
    • To exercise our right to freedom of expression and information.
    • To comply with the NDPR and relevant Nigerian laws.
    • For the performance of a task in the public interest or to exercise official authority vested in us.
    • To establish, exercise or defend legal claims.
    In these cases, we can restrict the processing instead of erasing your Personal Data if requested to do so by
    you.
    13.2 Requests to Object: You have the right to object at any time to the processing of your Personal Data
    if we process it based on our legitimate interests. This includes any so-called “profiling”. Our privacy
    notice informs you when we rely on legitimate interests to process your Personal Data. In these cases,
    we will stop processing your Personal Data unless we can demonstrate compelling legitimate reasons
    for continuing the processing. We may reject your request if the processing of your Personal Data is
    needed to establish, exercise or defend legal claims. You have the right to object at any time if we
    process your Personal Data for direct marketing purposes. You may also object at any time to
    profiling supporting our direct marketing. In such cases, we will stop processing your Personal Data
    when we receive your objection.
    13.3 Requests to Restrict: You have the right to ask us to restrict the processing of your Personal Data
    if:
    a) You contest the accuracy of your Personal Data, and we are in the process of verifying the
    Personal Data we hold.
    b) The processing is unlawful, and you do not want us to erase your Personal Data.
    c) We no longer need your Personal Data for the original purpose(s) of processing, but you
    need them to establish, exercise, or defend legal claims, and you do not want us to delete the
    Personal Data as a result, or
    d) You have objected to processing carried out because of our legitimate interests while
    verifying if our legitimate grounds override yours.
    If processing is restricted, we may process your Personal Data (excepting for storage purposes), only:
    • If you have given us your consent.
    • For establishing, exercising, or defending legal claims.
    • To protect the rights of another natural or legal person, or
    • For reasons of important public interest as defined under the NDPR and relevant Nigerian laws.
    Once processing is restricted following your request, we will inform you before we lift the restriction.
    13.4 Requests for Portability: If our processing is performed by computer and it is necessary to fulfil a
    contract with you or is based on your consent, you have the right to:
    a) Receive any Personal Data you have provided to us in a structured, commonly used, and machinereadable electronic format.
    b) Send your Personal Data to another organization or have us do so for you if it is technically feasible
    for us to do so.
    Suppose your request relates to a set of Personal Data that also concerns other individuals. In that case,
    the fact that you request that we port this data as described above does not preclude those individuals
    from exercising their rights regarding their Personal Data.
    Even if you request the portability of your Personal Data, you retain your right to also request their
    erasure.
    13.5 Requests to Object to Automated Decisions: Generally, you have the right to object to any decision
    producing a legal effect concerning you or which otherwise significantly affects you if this is based
    solely on your personal data’s automated processing. This includes automated decisions based on
    profiling.
    We may refuse your request if the decision in question is:
    a) Necessary to enter a contract with you or for the performance of your contract with us.
    b) Permitted by regulations, or
    c) Based on your explicit consent.
    We will only make decisions relying solely on automated processing that involve your sensitive
    Personal Data if you have given your explicit consent or the processing is necessary for reasons of
    substantial public interest, based on the Nigerian Data Protection Regulation and relevant laws.
12. Email Communications
    From time to time, Skoolbod may contact you via email to provide announcements, promotional offers,
    alerts, confirmations, surveys, and/or other general communication. To improve our Services, we may
    receive a notification when you open an email from Skoolbod or click on a link therein. If you would like
    to stop receiving marketing or promotional communications via email from Skoolbod, you may opt out of
    such communications by sending us an email or clicking the unsubscribe button.
13. External Data Storage Sites
    We may store your data on servers provided by third-party hosting vendors we have contracted.
14. Remedies for Violation and Timeframe for Remedy
    In the event of a violation of this Policy, our Data Protection Officer shall, within 7 days, redress the
    violation. Where the violation pertains to the disclosure of your Personal Data without your consent, such
    information shall be retracted immediately, and confirmation of the retraction sent to you within 48 hours
    of the redress.
15. Governing Law
    This Privacy Policy is made according to the Nigeria Data Protection Regulation (2019) or any other
    relevant Nigerian laws, regulations or international conventions applicable to Nigeria.
16. Changes to this Privacy Policy
    Skoolbod reserves the right to change this Privacy Policy from time to time. We will notify you about
    significant changes in how we treat personal information by sending a notice to the primary email address
    specified in your account, placing a prominent notice on our website, and/or by updating any privacy
    information. Your continued use of the website and/or Services available after such modifications will
    constitute your:
    (a) acknowledgment of the modified Privacy Policy; and
    (b) agreement to abide and be bound by that Policy.
17. Contact Information
    Skoolbod welcomes your questions or comments regarding this Statement of Privacy. If you believe that
    Skoolbod has not adhered to this Statement, please get in touch with Skoolbod at:
    Safsecurity technologies:
    Nigeria Address: Suite A109, 79/81 Obafemi Awolowo road, Ikeja, Lagos Nigeria
    USA Address: 108 West 13th Street, Wilmington, Delaware 19801 USA
    Tel: +2349040001999, +2349162816322
    Email Address: info@safsecurity.cloud
    Effective as of May 17, 2022