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CYSEC Academy is a trading name for Upgraded Era Solutions Ltd. This Privacy Policy governs the data protection standards by which CYSEC Academy (hereinafter "The Academy", "We", or "Us") processes the personal information of our data subjects. These include: Prospective or Enrolled Students, Instructors/Facilitators, Training Partners, and Website Visitors.

As a digital-first educational institution, we process data to deliver courses, programs, conduct assessments, and issue certifications. This policy is drafted in strict compliance with the Nigeria Data Protection Act (NDPA) 2023 and the General Data Protection Regulation (EU) 2016/679 (GDPR).

ARTICLE 1: DEFINITIONS

• "LMS": Learning Management System (the software platform where courses are hosted).

• "Student Record": The academic history, grades, and certification status of a learner.

• "Proctoring Data": Data collected during exams to ensure integrity (e.g., webcam snapshots, screen monitoring).

• "Instructor": A subject matter expert contracted to deliver content on the Platform.

ARTICLE 2: GOVERNING PRINCIPLES

In line with Section 24 of the NDPA and Article 5 of the GDPR, we ensure your data is:

1. Processed Lawfully: We only collect data needed for education and administration.

2. Purpose Limitation: Data collected for a specific course is not used for unrelated unauthorized purposes.

3. Data Minimization: We do not ask for excessive personal details if email suffices.

4. Accuracy: We maintain accurate records of your certification achievements.

5. Storage Limitation: We retain academic records for verification but delete temporary logs.

6. Integrity & Confidentiality: We protect your coursework and payment data.

ARTICLE 3: LAWFUL BASIS FOR PROCESSING

We process your data based on the following legal grounds:

3.1. Performance of Contract

• Scenario: When you purchase a course. We need your data to create your login, grant access to materials, and process your payment.

3.2. Legal Obligation

• Scenario: Keeping financial records for tax authorities and retaining student transcripts for accreditation compliance.

3.3. Legitimate Interest

• Scenario: Preventing account sharing (piracy), monitoring platform security, and recording live classes for quality assurance.

3.4. Consent

• Scenario: Subscribing to our newsletter or allowing us to use your testimonial/photo for marketing.

ARTICLE 4: SCOPE OF DATA COLLECTED

4.1. Student Data

• Identity: Full Name, Email, Phone Number, Profile Picture etc.

• Academic: Course Progress, Quiz Scores, Assignments, Certificates Earned.

• Financial: Payment Transaction IDs.

• Feedbacks

4.2. Instructor Data

• Professional: CV, Portfolio, Banking Details (for payouts), and Tax ID etc.

• Content: Video lessons, course materials, and responses to student queries.

4.3. Technical & Usage Data

• Logs: IP Address, Login Times, Device Type (used to detect unauthorized multiple logins).

• Cookies: Session tokens to keep you logged in to the LMS.

ARTICLE 5: SPECIFIC ED-TECH PROCESSING ACTIVITIES

5.1. Live Class Recordings

• Notice: Live sessions (e.g., via Zoom/Teams) may be recorded for students who missed the class to watch later.

• Privacy: If you turn on your camera or microphone during a live session, your image and voice will be captured in the recording. By joining, you consent to this processing.

5.2. Online Proctoring (Exams)

• To maintain the integrity of our certifications, we may use AI Proctoring Tools during final exams.

• Data Collected: Webcam video (to verify identity), Screen activity (to prevent switching tabs), and Audio.

• Retention: Proctoring data is reviewed by examiners and deleted after the exam grade is finalized/contested period expires.

5.3. Public Certificates

• Verification: Certificates issued by The Academy contain a unique ID/QR code.

• Disclosure: Third parties (e.g., potential employers) can validate the authenticity of your certificate on our verification portal using this ID. This reveals your Name, Course Title, and Date of Completion.

ARTICLE 6.1: THIRD-PARTY PROCESSORS

To provide a seamless learning experience, we share data with trusted partiess:

1. LMS Providers: (e.g., Canvas, Moodle) hosting our curriculum.

2. Payment Gateways: (e.g., Paystack, Stripe) for tuition collection.

3. Communication Tools: (e.g., Zoom, Slack, Discord) for community interaction.

4. Accreditation Partners: If a course is dual-certified, your results may be shared with the partnering body, University or Institute.

5. Our Group Companies: to better develop, modify, enhance or improve our services, communications for the benefits of our customers and/or to recommend related products that may be of interest.

6. Event attendees, exhibitors, partners and/or other participants where you have specifically requested a networking service from us in relation to an Event including the sharing your Information with these third parties.

7. Event sponsors when you register for, or attend a session or other part of our Event(s) that is sponsored by them. 

8.  Event exhibitors when you visit that exhibitor’s stand and permit your visitor badge to be scanned at their stand. 

9. Event service suppliers, such as the official suppliers of the following services: show guide production, event App, creative design for stand graphics, furniture hire, registration/badges and accommodation.

6.2 Third Party Websites

If you choose to visit a third party website in relation to our services, please be aware that your Information will be used in accordance with the privacy policy of that third party as published on their website, over which we have no control.

ARTICLE 7: INTERNATIONAL TRANSFERS

As an online academy with a global student base:

• We may transfer data to cloud servers (e.g., AWS, Azure) located in a different country than you reside.

• We ensure compliance by using Standard Contractual Clauses (SCCs) with our cloud providers to guarantee your data remains protected.

ARTICLE 8: DATA RETENTION

• Certification Records: Retained Perpetually. (Students often request proof of study years later; we must be able to verify this).

• Coursework/Assignments (if any): Retained for 24 Months after course completion, then archived or deleted.

• Inactive Accounts: Deleted after 10 Years of inactivity. This extended period allows for alumni re-engagement, retrieval of past academic history, and certificate verification. After this period, if no activity is recorded, the account and associated personal data will be permanently deleted or anonymized.

ARTICLE 9: YOUR RIGHTS

Under NDPA Part VI and GDPR Chapter III, you have the right to:

1. Access: E.g View your grade book and attendance history.

2. Rectification: Correct spelling errors on your certificate before it is issued.

3. Erasure: Delete your account (Note: This prevents us from verifying your certificate in the future).

4. Portability: Request a download of your data in a machine-readable format.

ARTICLE 10: SECURITY

We implement strict security measures to protect your learning journey:

• Encryption: All data in transit (video streams, payments) is encrypted via SSL/TLS.

• Access Control: Only authorized instructors and admins can view your grades.

• Password Policy: We enforce strong passwords to prevent account takeovers.

ARTICLE 11: CAVEAT ON WEBSITE LINKS

This website may contain links to other websites. Save and except as otherwise expressly stated by us, any link to another website is not covered by our privacy policy. We strongly advise that you should satisfy yourself with the details of any privacy policy provided on other websites or links.

ARTICLE 12: COOKIES POLICY

Customarily, websites are designed to collect certain information from the visitor. This website is also designed to collect your IP address and other information that your web browser typically shares with the websites that you visit. Our websites use cookies to enhance user experience.

• Essential Cookies: Necessary for the site to function (e.g., logging into the Academy portal).

• Analytics Cookies: Help us understand how visitors use our site (e.g., Google Analytics).

• Marketing Cookies: Used to deliver relevant ads (only with your consent).

• You can manage your cookie preferences via your browser settings.

For more information: Cookie Policy

ARTICLE 13: CONTACT & COMPLIANCE

If you wish to raise a complaint or question about how we use your Information, please contact the Data Protection Officer at

Data Protection Officer (DPO)

• Email: info@cysecacademy.com

Supervisory Authority

If you believe your rights have been violated:

• Nigeria Data Protection Commission: https://ndpc.gov.ng

• Information Commissioner’s Office: www.ico.org.uk

ARTICLE 14: ALTERATION OF PRIVACY POLICY

We reserve the right to update or amend the foregoing policy for the purposes of advancing data privacy rights, public interest or complying with lawful directives of the Federal Government - in accordance with changes in the GDPR, NDPA 2023 or Industry Regulations.

By continuing with this site, creating an account or enrolling in a course, you acknowledge that you have read and understood this Privacy Policy. 

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