LUMINATE E-LEARNING SOLUTION PRIVACY POLICY, TERMS & CONDITIONS OF USE & NDPR COMPLIANCE PRIVACY POLICY It is important to LUMINATE to help our service users retain their privacy when they take advantage of all the internet has to offer. Your privacy is important to you and to us. Therefore, we will protect the information you share with us. To protect your privacy, LUMINATE follows different principles in accordance with Nigeria Data Protection Regulation (NDPR) including global practices for users’ privacy and data protection. 1.0 Consent You accept this Privacy Policy when you sign up for, access, or use our website, products and services offered on this website and all related sites and applications. If you continue to use this website, you are agreeing to comply with and be bound by the terms and conditions of use, which together with our Privacy Policy govern the LUMINATE’s relationship with you in relation to this website. If you disagree with any part of these terms and conditions, you are not permitted to use this website. 2.0 Changes to our Privacy Policy We reserve the right to modify or amend this Privacy Policy at any time. All changes to this Privacy Policy will be effective immediately upon its posting on the website. We will notify you of changes to this Privacy Policy by clearly posting the changes in the website. Ensure you check this Policy regularly to stay updated with any amendment and understand how we use your information. Information collected before changes are made will be treated in accordance with the previous Privacy Policy. 3.0 Information We May Collect When you Browse on this Platform • Non-Personally Identifiable Information When you visit our website, we may passively collect non-personally identifiable information about you via certain Internet technology tools. This information consists of your IP address, cookies and web beacons, as well as information regarding the type of browser and operating system that you use, along with other similar analytic data. Your "IP address" is usually associated with the network location and physical location from which you enter the Internet. The term "cookies" refers to electronic data stored by your computer browser. The cookies enable us to facilitate your access to different aspects of our website. For example, by showing when and how you visit this website, cookies help us to see which pages of the website are popular and which are not. Cookies can also help us to improve your enjoyment of this website, for example, by remembering your address or other information when you request information or services on the website. Most web browsers automatically accept cookies, but you can disable this function so that your browser will not accept cookies. Please be aware that if you disable this function, it may affect your use and enjoyment of this website. • Personally Identifiable Information In your use of this website, we may collect any information that you voluntarily share with us. This information may be collected when you send us emails or voluntarily submit information to us via this website or inquiry page. This information may include your (1) contact information (such as name, address, email address and phone number), (2) age, (3) gender, (4) date of birth, and (5) any other information you choose to provide us, subject to applicable laws and the terms of this Privacy Policy. We may use third party service providers to assist us in collecting and maintaining this personally identifiable information. However, we require such service providers to maintain the confidentiality of such information. 4.0 How We Use the Information We Collect • Non-Personally Identifiable Information We use non-personally identifiable information in the aggregate to determine how much traffic the website receives, to statistically analyze its usage, to improve and customize the content of the website, layout and services. In addition, we may use your IP address to help diagnose problems with our server, to manage and to enhance the website based on the usage pattern data we receive. • Personally Identifiable Information We will use personally identifiable information for: (i) the purpose for which you provide it; (ii) as otherwise may be disclosed at the point of collection; and/or (iii) for the purposes described below. For example, we may use your contact information as provided to us in General Inquiries, such as email address, telephone number, and/or mailing address, to contact you regarding administrative notices and communications related to your use of the website or otherwise as you may request, such as for an employment application. In providing our services to you, your personal information may be disclosed to or collected by third party suppliers and service providers specifically involved in the processing of your information received via the website and as otherwise necessary to manage this website and provide the services you request. In addition, we may use your personal information in the aggregate in a non-identifiable way in order to better understand the services being provided, how to improve these services and how to improve the website. We may provide this aggregated information to third parties, but when we do so, we do not provide any of your information without your express permission. We may also use or disclose your personal information and review the status or activity of multiple users to resolve disputes, investigate problems, and enforce our Terms of Use or any other agreement with LUMINATE. We may disclose or access information whenever we believe in good faith that the law so requires, upon sale or reorganization of our organization or some or all of its assets, or if we otherwise consider it necessary to do so to maintain service and improve our products and services. Except as stated above, we will never sell, distribute, or release to a third party your personal information without your express permission. 5.0 Access to Your Personally Identifiable Information Upon written request and verification of your identity, we will provide you with your personal information in our possession as well as the personal information, if any, that we have disclosed to third parties. Requests for such information should be sent to the contact information below. 6.0 Handling of Electronic Records and Backup In general, we will retain all information collected through the website for, at a minimum, the length of time permitted by law. However, we will delete any personally identifiable information in our database upon your request or as otherwise required by law. We may, however, retain non-personally identifiable information indefinitely. We maintain backup files as a protection against natural disasters, equipment failures, or other disruptions. Backup files protect you and us because they lower the risk of losing valuable data. Backup files may contain records with your personal information. Removing a record from our active files and databases does not remove that record from any backup systems. Such backup data will eventually be passively deleted as backup records are erased through the normal recycling of backup files. In the meantime, as long as backup records exist, they receive the same security protections as our other records. 7.0 Security Communications between your browser and portions of this website containing personally identifiable information are protected with Secure Socket Layer (SSL) encryption. This encryption is to help protect your information while it is being transmitted. Once we receive your information, we strive to maintain the physical and electronic security of your personal information using commercially reasonable efforts. No data transmission over the internet or any wireless network can be guaranteed to be perfectly secured. As a result, while we strive to protect your personal information using commercially available and standard encryption technology, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk. 8.0 In the Event of a Security Breach of Your Personal Information If we determine that, your personal information has or may reasonably have been disclosed due to a security breach of our systems, we will notify you, at the contact information provided to us, in accordance with and to the extent required by applicable state and federal law. 9.0 Third Party Privacy Practices This Privacy Policy applies only to this website as provided by LUMINATE. This website may contain links to other websites, which may be subject to a different privacy policy or are otherwise maintained or provided by a third party. We are not responsible for the privacy practices of any third party website you access from this website. You should review the privacy policy of every website before using the website or submitting any information to the website. 10.0 Links to Other Websites Certain transaction processing channels may require links to other websites. Please note that LUMINATE is not responsible for and has no control over third party websites. We do not monitor or review the content of other party’s websites, which are linked from this website. Opinions expressed or materials appearing on such websites are not necessarily shared or endorsed by us, and LUMINATE should not be regarded as the publisher of such opinions or materials. Please be aware that we are not responsible for the privacy practices, or content of any third party sites and we encourage our users to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this website or accessed through this website yourself, before disclosing any personal information to it. LUMINATE will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information. 11.0 Contact Information If you have any questions or concerns about LUMINATE’s Privacy Policy or privacy practice, please contact us at: digital@luminate.ng or corporate@sidmach.com LUMINATE E-LEARNING POLICY ON CONSENT This website uses cookies and other methods to process data in order to customize and control your site experience, provide social media features, analyze our traffic and personalize advertising on our website. Please note that clicking on ‘Continue’ signifies acceptance to the Terms & Condition/Privacy Policy of this Site. For more information on how we process your personal data – please visit our privacy policy.