Privacy Policy

1. Introduction

EmmalGold Training Consult Limited (“EmmalGold”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, store, disclose and protect personal data when you visit our website, register for our programmes, contact us, participate in our training services, use our online services or student facilities, apply for opportunities advertised by us, or otherwise interact with EmmalGold.

We provide educational and training services, including international examination preparation, foreign-language training, academic tutoring, professional and educational guidance, and physical, online and hybrid learning programmes.

We process personal data in accordance with applicable Nigerian data-protection laws, including the Nigeria Data Protection Act 2023 and applicable regulations, directives and guidance issued by the Nigeria Data Protection Commission (NDPC).

By using our website or providing personal information to us, you acknowledge that you have read this Privacy Policy.

Where your consent is required for a particular processing activity, we will obtain that consent separately where appropriate.

2. Who We Are

For personal data for which we determine the purposes and means of processing, the data controller is:

3. Scope of This Privacy Policy

This Privacy Policy may apply when you interact with EmmalGold through:

• Our website;
• Online enquiry and contact forms;
• Course-registration forms;
• Student registration and onboarding;
• Student accounts or student dashboards;
• Physical classes;
• Online classes;
• Hybrid learning programmes;
• International examination-preparation programmes;
• Foreign-language training;
• Academic tutoring;
• Career or academic guidance services;
• Seminars, workshops and educational events;
• Email communications;
• Telephone communications;
• WhatsApp or other messaging services used by us;
• Online meeting or classroom platforms used for training;
• Job-vacancy applications submitted through our website or authorised channels;
• Surveys and feedback forms;
• Testimonials;
• Payment and transaction processes; and
• Other authorised EmmalGold services through which personal information is collected.

4. Personal Information We May Collect

The information we collect depends on how you interact with EmmalGold.

4.1 Personal Identification Information

This may include:

• Full name;
• Date of birth, where necessary;
• Age or age range, where necessary;
• Gender, where voluntarily provided and relevant;
• Photograph, where required for a particular service;
• Parent or guardian information where applicable; and
• Other information reasonably necessary to identify you or provide a requested service.

4.2 Contact Information

• Email address;
• Telephone number;
• WhatsApp number;
• Residential or correspondence address, where required; and
• Emergency or parent/guardian contact details where appropriate.

4.3 Educational Information

• Current educational level;
• Academic qualifications;
• Educational institution;
• Examination history;
• Previous examination scores;
• Target examination or qualification;
• Target score;
• Preferred course;
• Language-proficiency level;
• Learning goals;
• Academic strengths and areas requiring improvement;
• Course progress;
• Attendance information;
• Assessment and mock-examination results; and
• Tutor feedback.

4.4 Programme and Registration Information

• Course or programme selected;
• Preferred learning mode;
• Physical, online or hybrid class preference;
• Preferred class schedule;
• Registration date;
• Course level;
• Programme duration;
• Student identification or account details;
• Class attendance information; and
• Other information necessary for course administration.

4.5 Payment and Transaction Information

Where payment facilities are provided, we may process information such as:

• Amount paid;
• Payment date;
• Transaction reference;
• Payment status;
• Invoice or receipt information; and
• Other transaction-related records.

Where payments are processed by an independent payment-service provider, that provider may collect payment-card, bank or other financial information directly from you in accordance with its own privacy policy and security practices.

EmmalGold will only receive and retain payment information that is necessary for our legitimate business, accounting and course-administration purposes.

4.6 Communications

• Website messages;
• Emails;
• WhatsApp messages;
• Enquiries;
• Complaints;
• Customer-support communications;
• Feedback;
• Requests; and
• Records of our responses to you.

4.7 Job Application Information

Where you apply for a vacancy advertised by EmmalGold, we may process:

• Your name;
• Contact information;
• Curriculum vitae or résumé;
• Educational qualifications;
• Employment history;
• Professional skills;
• Certifications;
• Portfolio or work samples;
• References; and
• Other information voluntarily included in your application.

Job-applicant information will primarily be used for recruitment and related administrative purposes.

4.8 Technical and Website Information

When you visit our website, certain technical information may be collected automatically, depending on the technologies enabled on the website.

• IP address;
• Browser type;
• Device type;
• Operating system;
• Pages visited;
• Date and time of access;
• Referring website;
• Website interactions;
• Session information;
• Cookie identifiers; and
• General website-usage information.

5. How We Collect Personal Information

Directly From You

For example, when you:

• Complete a form;
• Register for a programme;
• Create an account;
• Contact us;
• Make an enquiry;
• Make a payment;
• Communicate with a tutor or administrator;
• Apply for a vacancy;
• Attend a class or programme;
• Participate in a survey; or
• Submit feedback.

From a Parent or Guardian

We may receive information from a parent or guardian where a learner is a child or another person is authorised to act on the learner's behalf.

Automatically Through Our Website

Information may be collected through permitted cookies, server logs and similar website technologies.

From Service Providers

We may receive information where necessary to operate our services, such as payment confirmation or information generated through an authorised learning, communication or technical platform.

We will not intentionally obtain personal information through unlawful or deceptive means.

6. Why We Use Your Personal Information

We may process personal information for purposes including:

• Registering students for courses and programmes;
• Providing educational and training services;
• Managing physical, online and hybrid classes;
• Creating and administering student accounts;
• Communicating class schedules and updates;
• Providing educational materials;
• Monitoring attendance and academic progress;
• Administering assessments and mock examinations;
• Providing personalised academic or examination-preparation support;
• Responding to enquiries;
• Providing customer and student support;
• Processing payments;
• Maintaining transaction records;
• Issuing invoices and receipts;
• Communicating administrative information;
• Managing tutor-student interactions;
• Improving our programmes and services;
• Maintaining website security and functionality;
• Preventing fraud, misuse or security incidents;
• Managing complaints and disputes;
• Maintaining legally required business, accounting or tax records;
• Managing employment applications;
• Conducting surveys and obtaining feedback;
• Sending permitted marketing communications;
• Complying with legal or regulatory requirements; and
• Establishing, exercising or defending legal rights.

We will not use your personal information for purposes materially incompatible with the purpose for which it was collected unless permitted by applicable law or any additional required consent is obtained.

7. Lawful Bases for Processing

Depending on the particular processing activity, we may rely on one or more recognised lawful bases.

Consent

We may process your information where you have freely provided valid consent. Where we rely upon consent, you may withdraw it subject to applicable law.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Contractual Necessity

We may process information where necessary to:

• Register you for a programme;
• Provide a service you requested;
• Manage your enrolment;
• Administer your classes; or
• Take steps at your request before entering into an agreement with you.

Legal Obligation

We may process information where necessary to comply with applicable laws, regulations, court orders, regulatory requirements, accounting requirements or other lawful obligations.

Legitimate Interests

Where permitted by law, we may process information where necessary for a legitimate business interest, provided the processing does not improperly override your rights and interests.

Vital Interests

In exceptional circumstances, information may be processed where necessary to protect the vital interests of an individual or another person, as permitted by law.

8. Marketing Communications

We may occasionally provide information about:

• New programmes;
• Upcoming classes;
• Educational opportunities;
• Events;
• Seminars;
• Workshops;
• Learning resources;
• Promotions; or
• Other EmmalGold services.

Where consent is required for direct marketing, we will seek your consent before sending such communications.

You may withdraw your marketing consent or unsubscribe from marketing communications at any time through the method provided in the communication or by contacting us.

Necessary administrative or service-related communications may still be sent where required to provide a service you requested.

9. Cookies and Similar Technologies

Our website may use cookies or similar technologies to operate correctly, remember preferences, understand website usage, improve performance and provide relevant functionality.

Necessary Cookies

These support functions required for the website or requested services to operate properly.

Preference Cookies

These may remember choices you make when using the website.

Analytics Cookies

Where enabled, these may help us understand how visitors use the website and identify opportunities to improve its performance.

Marketing Cookies

Where implemented, these may support advertising or promotional activities.

Where applicable law requires consent for a particular cookie or tracking technology, we will seek the required consent before using it.

10. Disclosure of Personal Information

We do not sell personal information.

We may disclose information to carefully selected third parties where necessary and legally permitted, including:

• Website-hosting providers;
• IT service providers;
• Cloud-storage providers;
• Learning-management or online-class providers;
• Communication and messaging providers;
• Video-conferencing or virtual-classroom providers;
• Payment-service providers;
• Professional advisers such as accountants, auditors or lawyers;
• Contractors or consultants providing services to EmmalGold;
• Examination or educational service providers where relevant to a requested service; and
• Government agencies, courts, regulators or law-enforcement authorities where disclosure is lawfully required.

Where a third party processes personal information on our behalf, we seek to use providers that offer appropriate privacy and security safeguards.

11. Third-Party Websites and Platforms

Our website may contain links to third-party websites, communication platforms, payment platforms, educational resources, social-media services or other external services.

Following an external link may result in your information being processed by an organisation operating independently from EmmalGold.

We do not control the privacy practices of independent third parties and encourage you to review their privacy policies before submitting personal information.

12. International Transfers of Personal Data

Some technology, hosting, communication, cloud, payment or online-learning service providers used by EmmalGold may operate infrastructure outside Nigeria.

As a result, personal information may, where necessary, be transferred to or processed in another country.

Where an international transfer occurs, we will take appropriate steps required by applicable Nigerian data-protection law to ensure that the transfer has a valid legal basis and appropriate safeguards.

13. Personal Data of Children

Some educational services offered by EmmalGold may be relevant to individuals under the age of 18.

We recognise that children's personal information requires additional protection.

Where consent is the lawful basis relied upon for processing a child's personal data, we will obtain consent from a parent or legal guardian where required by applicable law and may use appropriate methods to verify age and parental or guardian authority.

We seek to collect only information reasonably necessary for the educational service concerned.

Parents or legal guardians may contact us regarding personal information relating to a child for whom they have legal responsibility.

14. Sensitive Personal Data

We do not seek to collect sensitive personal information unless it is reasonably necessary for a legitimate purpose and its collection and use are permitted by applicable law.

Where sensitive personal data must be processed, we will apply the appropriate lawful basis, safeguards and consent requirements applicable to that processing.

15. Artificial Intelligence and Automated Technologies

Where EmmalGold introduces an artificial-intelligence-enabled assistant, chatbot, automated support system or similar technology, information submitted through that feature may be processed to provide the requested response or service.

Where an external technology provider supports such a feature, information may also be processed by that provider subject to appropriate contractual, privacy and data-protection safeguards.

Users should avoid submitting unnecessary confidential or sensitive personal information to automated systems.

Where a decision producing significant legal or similar effects is made solely through automated processing, we will apply the safeguards and rights required by applicable law, including human intervention where required.

16. Data Security

We take reasonable organisational and technical measures designed to protect personal information against:

• Unauthorised access;
• Unauthorised disclosure;
• Accidental loss;
• Destruction;
• Alteration;
• Misuse; and
• Other unlawful processing.

Depending on the circumstances, these measures may include:

• Access controls;
• Password protection;
• Secure hosting;
• Role-based access;
• Staff confidentiality requirements;
• Data backups;
• Software and system updates;
• Secure communication practices; and
• Other reasonable information-security controls.

No internet transmission, website, electronic storage system or communication platform can be guaranteed to be completely secure.

Where a personal-data breach occurs, we will investigate the incident and make notifications to the relevant authorities and/or affected persons where required by applicable law.

17. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected or for another lawful purpose.

The appropriate retention period may depend on:

• The nature of the information;
• The service provided;
• The duration of a student's programme;
• The existence of an ongoing relationship with you;
• Accounting and tax requirements;
• Regulatory requirements;
• Contractual requirements;
• The need to resolve complaints or disputes;
• Applicable limitation periods;
• Security requirements; and
• Other legal obligations.

When information is no longer reasonably required, we will take appropriate steps to delete, anonymise or securely dispose of it, subject to applicable requirements.

18. Your Data-Protection Rights

Subject to applicable Nigerian law, you may have rights relating to your personal information.

Right to Be Informed

You have the right to receive information about how your personal information is collected and used.

Right of Access

You may request confirmation of whether we process your personal information and request access to information we hold about you, subject to applicable exceptions.

Right to Rectification

You may request correction of personal information that is inaccurate or incomplete.

Right to Erasure

Where applicable legal requirements are satisfied, you may request deletion of your personal information.

Right to Restrict Processing

You may request restriction of certain processing activities in circumstances provided by law.

Right to Object

You may object to certain processing of your personal information, subject to applicable legal requirements.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent.

Right to Data Portability

Where applicable, you may request personal information in a structured and commonly usable format or request that it be transferred as permitted by law.

Rights Relating to Automated Decision-Making

Where applicable, you may have rights relating to decisions based solely on automated processing, including appropriate human intervention.

Right to Lodge a Complaint

You may lodge a complaint with the Nigeria Data Protection Commission if you believe your data-protection rights have been infringed.

19. Exercising Your Rights

To make a privacy request, please contact:

Please clearly describe the right you wish to exercise and provide sufficient information for us to identify the relevant records.

We may request reasonable information to verify your identity before fulfilling a request. This helps prevent unauthorised access to another person's information.

20. Complaints

If you have a concern about how EmmalGold processes your personal information, please contact us so that we can investigate and attempt to resolve the matter.

You may also have the right to lodge a complaint with Nigeria's data-protection supervisory authority:

21. Photographs, Video and Testimonials

From time to time, EmmalGold may wish to use photographs, video recordings, student success stories, testimonials or similar material for educational, informational or promotional purposes.

Where consent is legally required, we will obtain appropriate consent before using identifiable personal information for such purposes.

Where a child is involved, additional safeguards and parental or guardian consent requirements will be applied where required by law.

Providing a testimonial or agreeing to promotional use of an image will not normally be a condition of receiving educational services unless such use is genuinely necessary for the particular service.

22. Accuracy of Your Information

We encourage you to provide accurate and current information.

If your contact details or other important personal information change, you may contact us to request an update.

We may also take reasonable steps to maintain the accuracy of personal information where necessary for the purposes for which it is processed.

23. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time to reflect:

• Changes to our services;
• Changes to our website;
• New technologies;
• Changes to our data-processing practices;
• Changes to applicable law or regulatory guidance; or
• Other operational requirements.

When material changes are made, the revised Privacy Policy will be published on our website with an updated “Last Updated” date.

24. Contact Us

If you have questions, concerns or requests relating to this Privacy Policy or the processing of your personal information, please contact: