NYE Digital Academy ("NYE", "we", "us",
"our") is a digital learning platform that offers technology courses
to help our learners (“User”, “you”, “your”) develop in-demand skills, enhance
their career prospects, and stay competitive in today’s fast-evolving digital
landscape. Our
platform provides accessible, flexible, and high-quality learning experiences
in areas such as software development, data science, digital marketing, and
other technology-driven disciplines (our “Services”).
This Privacy Policy describes your privacy
rights regarding how and when NYE collects, uses, stores, shares and protects
your information across our website and Applications (“Apps”).
This Privacy Policy is applicable to the
website and applications (“Apps”) of NYE.
NYE’s Privacy Policy is embedded in the
following principles;
3.1.
To empower the individual: NYE wants you to be in charge of your
personal information and to make your own voluntary choices about your personal
data.
3.2.
To keep and secure personal information: NYE does not take
your trusting us with your information for granted. We take responsibility for
ensuring that appropriate security measures are put in place and your personal
information is protected.
3.3.
To be transparent and to educate users: For you to know what
personal information is, how we collect personal information, for what purpose
and how we secure personal information.
3.4.
To abide by local laws: We ensure that our privacy practices
reflect local practices and legal requirements.
3.5.
We work to have measures in place to prevent collecting and
storing personal data beyond what we need.
4.1.
Account: means your account which you will open on our
platform to access the technology courses.
4.2.
Cookies: A cookie is a small data file that is
transferred to your computer or mobile device. It enables us to remember your
account log-in information, IP addresses, web traffic, number of times you
visit, browser type and version, device details, date and time of visits.
4.3.
Data Breach: refers to the unauthorized access or
acquisition of computerized data that compromises the security, confidentiality
or integrity of personal information;
4.4.
Data Processing: means any operation or set of operations in
relation to such data, whatever the mechanism used, especially the obtaining,
recording, organization, retention, adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or otherwise
making available, alignment or combination, blocking, deletion or destruction;
4.5.
Data Protection Officer: refers to the individual that has been
assigned responsibility of managing the data protection program at NYE;
4.6.
Personal Information: Any information that can be used to identify
a living person including email address, name, password and address. It may
also include anonymous information that is linked to you, for example, your
internet protocol (IP), log-in information, address, location or device.
4.7.
Sites: means any platform including but not limited
to mobile applications, websites, and social media platforms.
4.8.
NYE means NYE Digital Academy.
4.9.
User: means an individual who uses the Services or
accesses the Sites and has agreed to use the Services.
5.1.
Identity Information
In opening an account with us, we collect the
following information from you;
Name
Address
Phone number
Email address
5.2.
Information We Receive From Your Devices
We may collect information from your device
such as the model, operating system and version, browser type, unique
identification number, presence of browser add-ons, the locations from where
you access our services and your stored contacts;
5.3.
Service Information
We collect information about how you use our
Service, your actions on our Platform, and your communications with us through
our Platform.
5.4.
Location Information
We may receive information from you that helps
us to approximate your location, such as using the IP address provided on your
browser or your device.
6.1.
We collect public and non-public data through your direct
disclosures to us when you use our Services or access our Platform, through
your communication to us through our customers support channels, when you read
our emails or notices, online research on social media and websites which may
not be publicly available, when you participate in surveys which we make
available to you;
6.2.
We collect information about you when you engage with us by using
our Services or accessing our Platforms through a variety of tracking
technologies which include cookies, flash objects, web beacons, file
information and similar technologies (“Tracking Technologies”);
We use your End User Information for a number
of purposes, including to operate, improve, and protect the services we
provide, and to develop new services. More specifically, we use your End User
Information to;
7.1.
Remember information about your use of our Services to make it
easier for you to navigate our Services when you access our Platforms
subsequently;
7.2.
Monitor aggregate metrics such as the total number of visitors,
traffic, usage and demographic pattern;
7.3.
Identify you across multiple devices;
7.4.
Provide custom, personalized content and information, including
targeted content and advertising;
7.5.
Diagnose or fix technology problems and otherwise plan for and
enhance our Services;
7.6.
Provide and monitor the effectiveness of our Services.
7.7.
To improve, enhance, modify, add to, and further develop our
services;
7.8.
To protect you
and NYE from fraud, malicious activity, and other
privacy and security-related concerns;
7.9.
To provide customer support to you including to help respond to
your inquiries related to our service or developers’ applications;
7.10.
To investigate any misuse of our service or developers’
applications, including criminal activity, or other unauthorized access to our
services; and
7.11.
For other notified purposes with your consent.
7.12.
We may also use one or more third party analytics services to
evaluate your use of our Services as the case may be and analyze performance
metrics. These third parties use cookies and other technologies to help
collect, analyze and provide us reports or other data.
8.1.
Your consent; One of the basis on which we process your
Personal Information is your consent where you agree to us collecting your
Personal Information by using our Services. You also have the choice at any
time to withdraw consent which you have provided.
8.2.
Legitimate Business Interests
Where allowed under the applicable law, we
rely on our legitimate business interests to process your data for the
following reasons;
8.2.1.
Protect you, our Services, and our Platform from malicious
activity and other privacy and security risks;
8.2.2.
Send technical notices, updates, security alerts, supports and
administrative messages;
8.2.3.
Promote analyze, modify and improve our Services, systems and tool, including the
reliability of the Services,
8.2.4.
Determine eligibility for NYE’s Services;
8.2.5.
Manage, operate and improve the performance of our Platform and
Services by understanding their effectiveness;
8.2.6.
Conduct aggregate analysis and develop business intelligence that
enables us to operate, protect, make informed decisions and report on the
performance of our business;
8.2.7.
Investigate any misuse of our Services or our Platforms;
8.2.8.
For any other purpose with your consent;
Our Platform may contain links to and from
third party websites. If you follow a link to any of these websites, please
note that these websites have their own privacy policies and that we do not
accept any responsibility for their policies. We strongly recommend that you
read their privacy policies and terms and conditions of use to understand how
they collect, use, and share information. We are not responsible for the
privacy practices or the content on the website of third party sites.
By virtue of the Nigeria Data Protection Act
(NDPA) and the Nigeria Data Protection Regulation, below are the rights you
have as a user in relation to your personal data:
10.1.
Right to be informed.
10.2.
Right to request access or copies to your Personal Information
held by us by signing into your Account or contacting us.
10.3.
Right to request that NYE erase your Personal Information; You have the right to ask
us to erase your Personal Information. Please note that this is a limited right
which applies where the data is no longer required, or the processing has no
legal justification or we are not required by law to retain your information.
The exceptions to this right is where the applicable law requires NYE to retain a historical archive or where we retain a core
set of your personal data to ensure we do not inadvertently contact you in
future where you object to your data being used for marketing purposes.
10.4.
Right to correct or rectify any Personal Information that you
provide which may be incorrect, out of date or inaccurate. You also have the
right to ask us to complete information you think is incomplete.
10.5.
Right to object to the processing of your Personal Information for
marketing purposes. You have a right to ask us not to contact you for marketing
purposes by adjusting your notification preference or by opting out via the
unsubscribe link in marketing emails we send you.
10.6.
Right to object to processing: You have the right to object to the
processing of your Personal Information in certain circumstances. Please note
that where you object to us processing your Personal Information, we might be
unable to provide the services to you.
10.7.
Right to not be subject to a decision based solely on automated
processing.
10.8.
Depending
on your location and subject to the applicable law, you may have the following
rights with respect to the data we collect about you;
10.8.1.
The
right to request confirmation of whether NYE processes data relating to you and
if so, to request a copy of such data;
10.8.2.
The
right to request that NYE erase your Personal Data in certain circumstances
provided by law;
10.8.3.
The
right to request that NYE rectifies or updates your Personal Data or Business
Information which is inaccurate, incomplete or outdated;
10.8.4.
The
right to request that we export your Personal Data that we hold to another
company where we believe it is technically feasible to do so;
10.8.5.
The
right to request that NYE restrict the use of your Personal Data in certain
circumstances, provided that you understand that the exercise of this right
might restrict your access to our Services;
10.8.6.
The right to withdraw your consent in
accordance with this Policy, where it has been previously given.
10.8.7.
You
may control our access to your Device through the settings app on your devices;
10.8.8.
If
you no longer want to receive marketing related emails from us, you may opt-out
via the unsubscribe link included in such email. We will try to comply with
your request as soon as practicable;
10.8.9.
In
the exercise of your rights above, you may contact us through such channel
provided under this Notice and we may request that you complete a form and
provide suitable identifications in order to verify your identity, and we will
provide you with requests as soon as possible;
10.8.10. If you wish to exercise any of the rights set above, please contact us at info@nyedigitalacademy.com
NYE maintains organizational, technical and
administrative measures designed to protect Personal Data covered by this
Policy against unauthorized access, disclosure, alteration, misuse and
destruction;
Unless otherwise specified in this Policy, we
limit access to your information to employees that have a business reason to
know such information and further implement security practices and procedures
designed to protect the confidentiality and security of such information and
prohibit unlawful disclosure of such information in accordance with our
policies;
To help us protect your data, we encourage you
to also maintain effective security measures and to utilize strong passwords
for your NYE Account. If you have reasons to believe that your interactions
with us is no longer secure, please contact us immediately;
We retain your data for as long as we are
providing our Services to you or for a period during which we reasonably
anticipate providing Services to you and in accordance with the provision of
the Nigerian Data Protection Act 2023.
For compliance reasons, we may further retain
your information for not longer than is necessary. The information we collect
through your use of our Services may be stored and processed in Nigeria or in
any other country where we maintain facilities;
Please note that we may transfer your data
including personal information to a country and jurisdiction that does not have
the same data protection laws as Nigeria. You acknowledge and agree to such
transfer by continued use of our services;
All data are stored in encrypted formats of
NYE’s database;
12.1.
We
may retain your data after you or your personal representative have requested
us to delete it if:
12.1.1.
We
are required to do so by an applicable law or;
12.1.2.
It
is necessary for our legitimate business interests such as enhancing the safety
of our Users.
NYE
ensures that personnel who collect, access and process Personal Information
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, the NDPA and the NDPR with regard to
the protection of Personal Information.
Cookies
are text files with small pieces of data sent to your device to enable us to
store information about you when you browse on our website if you agree.
We use cookies to distinguish you from other users and to customize and
improve our services.
Some browsers may automatically accept cookies while some can be
modified to decline cookies or alert you when a website wants to place a cookie
on your computer. If you do choose to disable cookies, it may limit your
ability to use our website.
We may also use one or more third party cookies to evaluate your use of
our Services as the case may be and analyze performance metrics. These third
parties use cookies and other technologies to help collect, analyze and provide
us reports or other data. By accessing and using our Services, you consent to
the processing of data about you by these analytics providers in the manner and
for the purposes set out in this Policy.
You can block cookies by activating a setting on your browser allowing
you to refuse the setting of cookies. You can also use our cookie banner to
manage your preferences. You can also delete cookies through your browser
settings. If you use your browser settings to disable, reject, or block cookies
(including essential cookies), certain parts of our website or app will not
function fully. In some cases, our website or app may not be accessible at all.
Please note that where third parties use cookies, we have no control over how
those third parties use those cookies.
We are
committed to protecting your privacy and ensuring the security of your personal
data. In compliance with the NDPA, we may conduct Data Protection Impact
Assessments (DPIAs) for certain data processing activities that involve high
risks to your privacy rights in order to identify and mitigate potential risks
associated with the processing of your personal data.
Periodically, NYE will grant access to the Nigeria Data Protection
Commission (NDPC) established by the NDPA for the monitoring, investigation,
report on the observance and promotion of the protection of the right to
privacy and of personal data.
Periodically, we may change, amend, or review this Privacy Policy to
reflect new services or changes in our Privacy Policy as guided by regulatory
requirements. All changes made will be posted on this page and where changes
will materially affect you, we will notify you of this change by placing a
notice on our website. If you keep using our Services, you consent to all
amendments of this Privacy Policy.
19.
Disputes Resolution and Filing of Complaints
Where any of your rights as provided for under
this Notice is breached, resolution shall be in accordance with the provision
of our Terms of Use, provided that you can only apply for a remedy within a
period of 2 years within which the breach occurred.
If you have any questions or complaints about the Terms or our privacy practices generally, you can contact us at info@nyedigitalacademy.com
20.
Governing Law
This Notice is made pursuant to the provisions of the NDPA and the NDPR
and in any event that any part of this Notice is found to be inconsistent with
the NDPA and the NDPR, such provision shall be deemed severed.
21.
Contact us
If you have any questions about this Policy, please contact us at info@nyedigitalacademy.com
22.
Version Control
This is the first version of this policy and
it was drafted in line with the provision of the Nigeria Data Protection Act
2023 (NDPA). If there is an update to the policy, the last updated date will be
amended.
