STEMRES LEARNING INITIATIVE PRIVACY POLICY STATEMENT

PRIVACY POLICY

Our Privacy Policy was last updated on June 10, 2022.

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you access and use our Website and products developed by us (our “Products”) and/or partake in any of our surveys or test and/or use products developed by our clients (“Client Products”) and informs you about your privacy rights and how the law protects you.

We use your Personal data to provide and improve product and the services we render to you. We also use your Personal Data in recording your personal experience, complaints and recommendations while testing or using Client Products. By using our Product, you agree to the collection and use of information in accordance with this Privacy Policy. 

INTERPRETATION AND DEFINITIONS

INTERPRETATION

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

DEFINITIONS

For the purposes of this Privacy Policy:

• “Account” means a unique account created for you to access our Products or Client Products.

• “Business“, for the purpose of the Companies and Allied Matters Act, 2020, as may be amended refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in Nigeria.

• “Clients” means the Company’s clients to whom it provides services including user research, data analysis, staff and students’ STEM education, training and workshops, product testing, among others. Clients may include but is not limited to private institutions, local and international technology companies, government and government agencies. 

• “Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Stemres Learning Initiative Limited (CAC/IT/NO117268)
  
  For the purpose of the NDPR, the Company is the Data Controller.

• “Country” refers to Nigeria

• “Consumer“, for the purpose of the NDPR means a natural person who is resident in Nigeria. 

• “Data Controller“, for the purposes of the NDPR refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• “Device” means any device that can access the Products and/or Client Products such as a computer, a cell phone or a digital tablet.

• “NDPR” means the Nigeria Data Protection Regulation (2019) and other regulations made pursuant to it.

• “Personal Data” is any information that relates to an identified or identifiable individual.
  
  For the purposes of NDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

• “Service Provider” means any natural or legal person who processes the data on behalf of the Company or as the Company’s client. It refers to third-party companies or individuals employed by the Company to facilitate the Products, to provide or improve the Products or Client’s Products on behalf of the Company, to perform services related to the Products or Client’s Product or to assist the Company in analyzing how the Products or Client’s Products are used. For the purpose of the NDPR, Service Providers are considered Data Processors.

• “Usage Data” refers to data collected automatically, either generated by the use of the Products and/or Client Products or from the Products and/or Client Products infrastructure itself (for example, the duration of a page visit).

• “Website” refers to the Company’s website accessible from stemres.net

COLLECTING AND USING YOUR PERSONAL DATA

TYPES OF DATA COLLECTED

PERSONAL DATA

While accessing our Products or Client Products, We may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Address, State, ZIP/Postal code, City

USAGE DATA

Usage Data is collected automatically when using the Product or Client Product.

Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Products and/or Client Product that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Products and/or Client Products by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you use the Product or Client Product through a mobile device.

USE OF YOUR PERSONAL DATA

The Company may use Personal Data for the following purposes:

• To provide and maintain our Products and/or Client Products, including to monitor the usage of our Products and/or Client Products.

• To manage your Account: to manage your registration as a user of the Products and/or Client Product. The Personal Data you provide can give you access to different functionalities of the Products and/or client Products that are available to you as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Products and/or Client Product.

• To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already accessed as a result of using the Product/Client Products or enquired about unless you have opted not to receive such information.

• To manage Your requests: To attend and manage your requests to Us.

• For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Products and/or Client Products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Products, for payment processing, to contact you.

• With Clients: We may share or transfer your personal information in connection with using our Client Products in which case, we will require our Clients to honor this Privacy Policy.

• For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

• With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any subsidiaries, joint venture partners or other companies that we control or that are under common control with Us.

• With business partners: We may share your information with our business partners to offer You certain products, services or promotions.

• With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

• With your consent: We may disclose Your personal information for any other purpose with Your consent.

RETENTION OF YOUR PERSONAL DATA

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or We are legally obligated to retain this data for longer time periods.

TRANSFER OF YOUR PERSONAL DATA

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

DISCLOSURE OF YOUR PERSONAL DATA

BUSINESS TRANSACTIONS

If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

LAW ENFORCEMENT

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Where this is the case, we would provide sufficient information to you before any such disclosure, provided that this is permitted by applicable law.

OTHER LEGAL REQUIREMENTS

The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

SECURITY OF YOUR PERSONAL DATA

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect your Personal Data, We cannot guarantee its absolute security.

DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA

The Service Providers we use and our Clients may have access to your Personal Data. These third-party vendors collect, store, use, process and transfer information about your activity on our Products and Client Products in accordance with their Privacy Policies.

ANALYTICS

We may use third-party Service providers to monitor and analyze the use of our Product and our Clients may also use third-party Service Providers to monitor and analyze the use of Client Products.

EMAIL MARKETING

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

PAYMENTS

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards and requirements necessary to help ensure the secure handling of payment information.

NDPR PRIVACY POLICY

Legal Basis for Processing Personal Data under NDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

• Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.

• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

YOUR RIGHTS UNDER THE NDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within Nigeria, to:

• Request access to your Personal Data. The right to access, update or delete the information We have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact Us to assist you. This also enables you to receive a copy of the Personal Data We hold about you.

• Request correction of the Personal Data that We hold about you. you have the right to have any incomplete or inaccurate information we hold about you corrected.

• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

• Request erasure of Your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.

• Withdraw Your consent. You have the right to withdraw your consent on using your Personal Data. If You withdraw your consent, We may not be able to provide you with access to certain specific functionalities of the Products or Client Products.

EXERCISING OF YOUR NDPR DATA PROTECTION RIGHTS

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, We will try our best to respond to you as soon as possible.

SALE OF PERSONAL INFORMATION OF MINORS UNDER 18 YEARS OF AGE

We do not knowingly collect personal information from minors under the age of 18 through our Products and Client Products, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of customers we actually know are less than 18 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the customer who is between 13 and 18 years of age, or the parent or guardian of a Customer less than 13 years of age. Customers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us.

If you have reason to believe that a child under the age of 13 (or 18) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

LINKS TO OTHER WEBSITES

Our Products may contain links to other websites that are not operated by us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

UNLAWFUL BREACHES 

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, we shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach in accordance with the requirements of the NDPR.

Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within 7 (Seven) days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.

CHANGES TO THIS PRIVACY POLICY

We may update Our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on our Products, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this Privacy Policy, You can contact us:

• By visiting this page on our website: contact us

• By sending us an email: info@stemres.net