Privacy Policy for AltSchool Africa Product

1. Introduction

altschoolafrica.com is provided by AltSchool Africa (“AltSchool”).

At AltSchool, we value your privacy, and we are committed to safeguarding your personal information. All personal data that you provide us will be protected and kept confidential among our affiliates, representatives, and privies.

Throughout the website, the terms “we”, “us” and “our” refer to AltSchool.

This Privacy Policy explains how we collect, use, share and protect your personal data in connection with your relationship with us as a learner or potential learner. It applies to all our learners, potential learners, applicants, partners and every other person we hold information about.

This policy also sets out your rights and who you may contact for further information.

By visiting our website, using our services, or signing up for our course, You agree to this Privacy Policy.

Your use of our services and any dispute over privacy is subject to this Policy and our Terms of Service including its applicable limitation on damages and resolution of disputes. Our Terms of Service are incorporated by reference into this Policy.

Our website and services are not directed at you if we are prohibited by any law of any jurisdiction from making the information on our website available to you and is not intended for any use that would be contrary to local law or regulation.

2. Definitions

“consent”

means the consent of the data subject which must be a freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they (by a statement or by a clear affirmative action) signify their agreement to the processing of personal data relating to them;

“data controller”

means the natural or legal person or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this policy, AltSchool is the data controller of all personal data relating to data subjects;

“data processor”

means a person or organisation which processes personal data on behalf of a data controller. This includes AltSchool, its employees and third-party service providers;

“Data Protection Legislation”

means all applicable data protection and privacy laws including, but not limited to the Nigerian Data Protection Act 2023, the Nigeria Data Protection Regulation 2019 (NDPR), the General Data Protection Regulation 2018 and the United Kingdom’s General Data Protection Regulation ((EU) 2016/679) (GDPR), the Data Protection Act 2018 and any successor legislation;

“Data Protection Office”

means an officer of AltSchool responsible for ensuring that all processing of personal data is in compliance with the Data Protection Legislation;

“data subject”

means a living, identified, or identifiable individual about whom AltSchool holds personal data;

“personal data”

means any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that data subject;

“personal data breach”

means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed;

“processing”

means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

"Learners/Applicant"

means any individual who has applied for admission to a course, program, or training offered by the institution, or who has been successfully enrolled as a participant in any of the educational services provided by AltSchool Africa. This includes but not limited to prospective learners, those who have been formally admitted and are learners actively participating in the learning process.

3. Data Protection Officer & Scope of Policy

3.1. AltSchool’s Data Protection Office contact information is [email protected]. The Data Protection Officer is responsible for working together with the HR Department in administering this policy and for developing and implementing any applicable related policies, procedures, and guidelines.

3.2. All managers, department heads and supervisors are responsible for ensuring that all employees, agents, contractors, or other parties working on behalf of AltSchool comply with this policy and, where applicable, must implement such practices, processes, controls, and training as are reasonably necessary to ensure such compliance.

3.3. Any questions relating to this policy, AltSchool’s collection, processing, or holding of personal data, or to the Data Protection Legislation should be referred to the Data Protection Officer.

4. Consent

4.1. Where processing of your personal data is based on consent, we shall obtain the requisite consent at the time of collection of the personal information. In this regard, you consent to the processing of your personal information when you access our website, or use our services, sign up or register for our course as well as when you engage with any content, features, technologies or functions offered on our website or other digital platforms. You can withdraw your consent at any time, but such withdrawal will not affect the lawfulness of the processing of your data based on consent given before its withdrawal.

4.2 Where your personal data is to be processed for a different purpose that is incompatible with the purpose or purposes for which that personal data was originally collected that was not disclosed to you when you first provided your consent, we will obtain your consent to the new purpose or purposes.

5. Age Restriction

5.1. You affirm that you are over 18 years old and have the right to contract in your own name, and that you have read the above authorisation and fully understand its contents

5.2. Individuals under 18 years old are only allowed to sign up for our services or provide us with their information when an adult above the age of 18 is signing contracts in their stead.

6. Data Protection Principles

The Data Protection Legislation sets out the following principles with which anyone handling personal data must comply. We, our employees, agents, contractors and third-party service providers comply with the following principles when collecting or processing your personal data. All personal data must be:

6.1. processed lawfully, fairly, and in a transparent manner in relation to the data subject;

6.2. collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

6.3. adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;

6.4. accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay;

6.5. kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection Legislation in order to safeguard the rights and freedoms of the data subject;

6.6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

7. Information We Collect.

In providing our educational services to you, we collect certain non-personal and personal data about you. Our policy is to keep this information confidential and strictly safeguarded and to use or disclose it only as needed to provide services to you, or as permitted or required by the Data Protection Legislation.

There are two categories of information we collect. We collect a variety of information from our users and visitors to our website. As described below, some information is automatically collected when you visit our website, and some you provide to us when filling out a form or communicating with us.

7.1. Information Collected Automatically: Whenever you visit our website, our web servers automatically collect non-personal information such as the domain name of the internet access provider, the internet protocol address used to connect the computer to the internet, the average time spent on our website, pages viewed, information searched for, access times, and other relevant statistics.

7.2. Information You Provide Us: ltSchool will collect personally identifiable information from Applicants at the point of registration. “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. If you provide us with Personally Identifiable Information, by contacting us or subscribing to our services we collect the following personal information:

7.2.1. Full legal name;

7.2.2. Email address and telephone number;

7.2.3. Physical address and country;

7.2.4. Means of identification;

7.2.5. Date of birth;

7.2.6 Username and password;

7.2.7 Contact information;

7.2.8 Educational information (e.g., academic history, CV, employment status etc.);

7.2.9 Financial information where you make any payment for our services; and

7.2.10 Any other information you provide to us

7.3 Your name must correspond with all government-issued legal documents such as travel passports, driver’s licenses, or original birth certificates. Once an Applicant’s name has been submitted at registration, it cannot be changed. This policy ensures that all records remain consistent, accurate, and protected throughout the Applicant’s time at AltSchool. Once registered, no changes, corrections, updates, or modifications can be made to the User’s name except by providing a duly notarized affidavit.

7.4 Your email address is for the purpose of communicating important updates regarding your registration, enrolment, and participation in our programs. Your email address may also be used to send you relevant information about the program, including program announcements, deadlines, access to grades, the learning management system, and the portal. Email addresses provided during registration are considered final and cannot be changed after registration. Applicants are advised to use email addresses they can access for the next 12-15 months.

7.5 Your date of birth provided during registration is considered final and cannot be changed after registration. In other words, the date of birth you submit during your initial registration will remain in our records throughout your time at AltSchool. For example, if an Applicant registers with the DOB "01/01/1999" and wishes to change it to "02/01/1999," such a request will not be allowed except you provide a notarized affidavit to that effect.

8. Using Your Personal Data

8.1. We primarily collect your personal data to ensure that we provide the most efficient educational service to you, monitor the use and improve our website and other legitimate interests. Your information will solely be used and disclosed for the following purposes:

8.1.1. To help us verify your identity;

8.1.2. To carry out our obligations ensuing from any contracts entered into between you and us;

8.1.3. To provide you with the products, services and information you request from us;

8.1.4. To assist you with enquiries and improve our customer service;

8.1.5. To assist us in carrying out marketing analysis and customer profiling (including transactional information), conduct research, including creating statistical and testing information;

8.1.6. To allow us to communicate with you in any way (including e-mail, telephone, visit, and text or multimedia messages);

8.1.7.For our billing and account purposes;

8.1.8. To help prevent and detect fraud or loss;

8.1.9. To update our records;

8.1.10. To make recommendations and suggestions to you about services offered by us unless you have previously asked us not to do so;

8.1.11. To send you service or support messages, such as updates, security alerts, email notifications and /or newsletters;

8.1.12. To conduct investigations and risk assessments; and

8.1.13. For compliance with legal and regulatory obligations.

8.2.Employees, agents, contractors, or other parties working on behalf of AltSchool shall collect your personal data only to the extent required for the performance of their job duties and only in accordance with this policy. Excessive personal data must not be collected.

8.3. Employees, agents, contractors, or other parties working on behalf of AltSchool shall process your personal data only when the performance of their job duties requires it. Your personal data held by AltSchool cannot be processed for any unrelated reasons.

9. Sharing Your Personal Datay

AltSchool does not sell, trade or rent personal data to anyone. Further, we will not share or disclose your data with or to a third party without your consent except as necessary to provide the Services or as described in this Policy. We may share your personal data with any or all of the following:

9.1 Service providers: We share personal data with vendors or agents working on our behalf for the purpose of providing the necessary services or as described in this Policy. For example, companies we've hired to provide customer service support, to protect and secure our systems and services, or to perform sanctions screening and identity verification services may need access to personal data to provide those functions. The processing by such third parties shall be governed by a written contract with AltSchool to ensure adequate protection and security measures are put in place for the protection of personal data in accordance with the terms of this Policy.

9.2 Financial services & payment processing: When you provide payment data, for example, to make a payment, we will share payment and transactional data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services.

9.3 Affiliates: We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access is needed to provide services and operate our business.

9.4 Partners: We may share your data with companies we partner with for industry networking events, mixers, and other learning and development opportunities, but only with your explicit consent and with the option to opt out.

9.5 Corporate transactions: We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, transfer, divestiture, or sale of all or a portion of our business or assets.

9.6 Law enforcement or regulatory directive: We may access, disclose, and preserve personal data in accordance with applicable law and when we believe that doing so is necessary to comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies.

9.7 Security, safety, and protecting rights: We will disclose personal data if we believe it is necessary to:

9.7.1 protect our users and others, for example, to prevent fraud or to help prevent the loss of life or serious injury of anyone;

9.7.2 operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or

9.7.3 protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.

Please note that any third parties you contract with have their respective privacy policies and AltSchool is not responsible for their actions, including their data protection practices. If you provide personal data to any third parties or allow us to share personal data with them, that data is governed by their privacy policies.

10. Data Accuracy

Your personal data must be accurate and kept up to date. In this regard, AltSchool shall ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to you; make efforts to keep your personal data updated where reasonable and applicable; and make timely efforts to correct or erase your personal data when inaccuracies are discovered. AltSchool Africa is not responsible for any issues or delays resulting from inaccurate or outdated information. If we discover that the information provided is incorrect, we reserve the right to request updated details and, in certain cases, suspend or terminate the application process until the information is corrected.

11. Data Retention

AltSchool shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed. In the case of your educational data, the purpose for which the data was collected is to provide you with our educational services which will equip you with technical skills needed for the careers of the future. Unless AltSchool receives a valid request to erase your educational data, the data is retained permanently. This allows your record of participation and progress in our educational program to be maintained. If the data were deleted, we would have no record of your performance and completion of our educational program.

12. Other Information We Collect

Other information which may be automatically collected from you when you visit our website include; domain name of your internet service provider, the internet protocol address used to connect the computer to the internet, the average time spent on our website, pages viewed, information searched for, access times, your geographical location, operating system, referral source, and other relevant statistics.

We may also collect information from you using cookies and other analytical tools especially when you use our products and services. More details are provided below in our section on Cookies. .

13. Data Confidentiality

Your information is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions. You have the right to request copies of any and all information we keep on you, if such requests are made in compliance with applicable laws and other relevant enactments. While we are responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our premises, dealing with only authorized officers of AltSchool.

14. Disclosures

14.1. We will not sell, publish, or disclose to third parties your personal data collected on our website, through our servers or otherwise obtained by us, other than to provide our services and as set forth in this policy. We may share generic aggregated demographic information not linked to any personally identifiable information regarding visitors and users with our business partners, trusted affiliates, professional advisers and advertisers for the purposes outlined above. We may share your information with these third parties for those limited purposes if you have given us your permission and in compliance with the Data Protection Legislation.

14.2. We may request and provide information about you from and to third parties to provide our services.

14.3. We will notify you as soon as we become aware of a harmful data breach which may result in a risk of your rights and freedom.

14.4. You have the right to request an erasure of your data at any time.

14.5. We will notify you if we are transferring your data.

14.6. You may request at any time that we halt further dissemination of your data or cease to use your data.

14.7. 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.

14.8. 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.

14.9. TTo 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.

15. Transfer of Personal Data

15.1. Third Party Processor

We may engage the services of third parties in order to process your personal data. The processing by such third parties shall be governed by a written contract with AltSchool to ensure adequate protection and security measures are put in place by the third party for the protection of your personal data in accordance with the terms of this policy and the Data Protection Regulation.

15.2. International Transfers

We have offices and facilities in Nigeria, [Insert other office locations]. To operate our business and provide you with our services, we may send your personal information to our other offices and outside of your country. Your personal information may be subject to the laws of the countries where we send it. When we send your information outside of your country of origin or residence, we shall ensure your personal information is protected, and only send your information to countries that have strong data protection laws.

15.3. **Transfer of Personal Data of UK Citizens and Citizens of an EU Country to Foreign Country **

15.3.1. Where your personal data is to be transferred to a country outside the United Kingdom (UK) or the EU, AltSchool shall put adequate measures in place to ensure the security of such data. In particular, AltSchool shall, among other things, conduct a detailed assessment of whether there are issued regulations confirming that country in question ensures adequate level of protection.

15.3.2. Transfer of your personal data to a country outside the UK or the EU would be in accordance with the provisions of the GDPR. AltSchool will therefore only transfer your personal data out of the UK or the EU on one of the following conditions:

a. Your explicit consent has been obtained;

b. The transfer is necessary for the performance of a contract between you and AltSchool;

c. The transfer is necessary to conclude a contract between AltSchool and a third party in your interest;

d. The transfer is necessary for reason of public interest;

e. The transfer is for the establishment, exercise or defense of legal claims;

f. The transfer is necessary in order to protect your vital interests or the interests of other persons, where you are physically or legally incapable of giving consent.

15.3.3. Provided, in all circumstances, that you have been manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country, this provision shall not apply to any instance where you are answerable in duly established legal action for any civil or criminal claim in another country.

15.3.4. We will take all necessary steps to ensure that your personal data is transmitted in a safe and secure manner. Details of the protection given to your I nformation when it is transferred outside the UK or the EU shall be provided to you upon request.

15.3.5. Where the recipient country does not ensure adequate an adequate level of protection and none of the conditions stipulated in clause 14.3.2 of this policy is met, AltSchool will engage with the Information Commissioner’s Office for approval with respect to such transfer.

15.4. **Transfer of Personal Data of Nigerian Citizens to a Foreign Country **

15.4.1. Where your personal data is to be transferred to a country outside Nigeria, AltSchool shall put adequate measures in place to ensure the security of such data. In particular, AltSchool shall ensure that such transfer is in accordance with Data Protection Laws and that the foreign country receiving such data has adequate data protection laws. We will also always document the basis of such international transfers and the adequacy of data protection relied upon.

15.4.2. 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.

15.4.3. 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.

16. Your Rights

Subject to certain limitations and exceptions, you are entitled to the following principal rights under the Data Protection Legislation:

16.1. You have the right to be notified if we are transferring your personal information.

16.2. You have the right to request an erasure of your personal data at any time.

16.3. You have the right to request that we rectify inaccurate personal information.

16.4. You may request at any time that we halt further dissemination of your data or cease to use your personal information.

16.5. You have the right to request for copies of your personal information.

17. Website Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as secure sockets layer (SSL) to safeguard and secure the information we collect online. We use encryption tools when accepting and transmitting delicate visitor information through our website. Some of the other safeguards we use are firewalls and physical access controls to our data centres, and information access authorization controls.

18. Training

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 Data Protection Legislation with regard to the protection of personal data. On an annual basis, we shall develop a capacity building plan for our employees on data privacy and protection in accordance with the Data Protection Legislation.

19. Use of Cookies

We use cookies to identify you as a user and make your user experience easier, customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies allow our servers to remember your account log-in information when you visit our website, IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities. If your browser or browser add-on permits, you have the choice to disable cookies on our website; however, this may limit your ability to use our website.

20. 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.

We are statutory obligated to retain the data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud and in compliance with laws and regulatory guidelines applicable to us.

21. Data Breach Management Procedure

21.1. 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:

21.1.1. notify you within 24 hours of the occurrence of the data breach; \

21.1.2. properly investigate the breach and take the necessary steps to mitigate such breach;

21.1.3. identify remediation requirements and track the resolution of such breach; and

21.1.4. notify the Information Commissioner’s Office or any other regulatory authority, where necessary.

22. Links to Third Party Websites

22.1. Our website may contain links to third-party websites or services that are not owned or controlled by us.

22.2. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such websites or services.

22.3. We strongly advise you to read the terms and conditions and privacy policies of any third-party websites or services that you visit.

23. Limitation of Liability

We exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, we will not be liable for unauthorised disclosure of personal data that occurs through no fault of ours.

24. Changes to this Privacy Policy

AltSchool reserves the right to make changes or update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or regulatory obligations. Whenever such changes are made, we will notify you by posting a prominent notice on our website and if appropriate, by emailing You directly using the contact information provided during your registration process. These changes will take effect immediately after you have been notified.

By continuing to use our services after any updates to this policy, you confirm your acceptance of the revised terms.

25. Contact Us

If you would like more information or you have any comments or questions on our Privacy Policy, please contact us at [email protected].

This policy is effective as of 11 October 2024 Last updated: 11/10/2024