1. Introduction

Welcome to Lumilearn's Data Protection Policy. At Lumilearn, we're committed to protecting your privacy and securing your personal data in compliance with Nigerian data protection laws and GDPR, including the Nigeria Data Protection Act (NDPA) 2023. This policy explains how we handle your information as you use our e-learning platform and services.

By using Lumilearn, you consent to the practices described in this policy.

2. Scope & Data Controller

This policy applies to all personal data we process through Lumilearn's website, apps, and services, primarily concerning individuals in Nigeria. Lumilearn, Inc., registered in Nigeria, is the data controller responsible for your personal data.

3. Data We Collect

We collect information to provide and enhance your learning experience. This includes:

• Account & Profile Data: Your name, email, password, location, and optional profile details (like a photo or background).
• Learning Activity Data: Your course progress, scores, forum contributions, certificates, and video watch history.
• Payment Data: Necessary details for purchases, which are processed securely by trusted third parties.
• Communication Data: Your interactions with our support team and any surveys you complete.
• Technical & Usage Data: Your IP address, device info, pages visited, and other platform usage analytics.
• User-Generated Content: Assignments, posts, and any other content you create on the platform.
• Sensitive Personal Data: We only collect this when strictly necessary and with your explicit consent (e.g., for accessibility accommodations if you provide health information).

4. How We Use Your Data

We use your data based on lawful grounds (like fulfilling our contract with you, our legitimate business interests, your consent, or legal obligations) to:

• Provide and manage your courses and services.
• Personalize your learning and improve our platform.
• Communicate with you (updates, support, and marketing with your consent).
• Ensure platform security and smooth operations.
• Conduct research and analytics, often using data that can't identify you personally.
• Comply with legal obligations.

5. Data Storage & Security

Your data is stored securely on encrypted servers. We put strong technical and organizational measures in place to protect against unauthorized access, loss, or damage, demonstrating our duty of care under the NDPA/GDPR.

6. Data Sharing & Transfer

We don't sell or rent your personal data. We may share data with:

• Your Consent: When you explicitly agree.
• Content Partners/Instructors: For course administration.
• Service Providers: Trusted third parties who help us operate our platform (e.g., cloud hosting, payment processors).
• Legal Requirements: When required by Nigerian law or a court order.
• Business Transfers: In case of mergers or acquisitions.
• Aggregated/Anonymized Data: Information that can't identify you personally.

7. International Data Transfers

Your data might be transferred outside Nigeria (e.g., for cloud services). Any such transfer complies with NDPA Section 41, ensuring adequate protection or appropriate safeguards are in place.

8. Your Rights (Data Subject Rights)

Under the NDPA, you have rights regarding your personal data, including the right to:

• Access your data.
• Request correction or erasure.
• Object to processing.
• Request data portability.
• Withdraw consent.
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC).

To exercise these rights, please contact us using the information below.

9. Data Retention

We keep your personal data only for as long as necessary to provide our services, fulfill the purposes outlined in this policy, and comply with legal obligations.

10. Children's Privacy

Lumilearn's platform is designed for learners of all ages. However, individuals under the age of 18 (or lacking the legal capacity to consent under Nigerian law) cannot create an account on Lumilearn without the express consent of their parent or legal guardian. If we find an account created by someone under 18 without verifiable parental consent, we'll disable the account and promptly delete associated personal data.

11. Compliance

Lumilearn strictly complies with the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR) 2019.

12. Data Breach Notification

In the event of a personal data breach posing a high risk to your rights, we will notify the NDPC within 72 hours and inform affected individuals without undue delay, as required by the NDPA.

13. Policy Updates

We may update this policy periodically to reflect changes in our practices or legal requirements. We'll notify users of significant changes via our platform. Your continued use implies acceptance of the updated policy.

14. Contact Information

For any privacy inquiries, requests, or concerns regarding this Data Protection Policy or our data processing practices, please contact us at:

15. Acceptance of Policy

By using Lumilearn's services, you agree to the terms of this Data Protection Policy.