Privacy Policy

This Privacy Policy explains how eDeafy collects, uses, stores, shares, protects, and retains personal data when you use the eDeafy website, web application, mobile application, course platform, dashboards, certificates, community features, support channels, and related services (collectively, the "Platform").

eDeafy is an accessibility-first learning platform designed to support deaf and hard-of-hearing learners through sign-language-supported learning. Because our Platform may process accessibility preferences and disability-related information, we treat privacy, dignity, consent, and data minimisation as core compliance commitments.

This Policy applies to Learners, Trainers, Organisations, Interpreters, visitors, and other users of the Platform.

eDeafy is an early-stage accessibility-first learning platform and project currently operated from Nigeria. Until eDeafy confirms its final incorporated entity details, this Policy uses "eDeafy", "we", "us", and "our" to refer to the operators of the eDeafy Learning Platform who are responsible for personal data collected through the Platform.

• Privacy and Legal: legal@edeafy.com
• General Support: support@edeafy.com
• Website: www.edeafy.com

eDeafy is currently operated from Nigeria with a vision to serve users and partners globally. We process personal data in accordance with applicable Nigerian data protection law, including the Nigeria Data Protection Act 2023 and relevant regulations, guidance, and lawful directives issued by the Nigeria Data Protection Commission.

As the Platform expands, we aim to align our privacy practices with recognised global data protection principles, including transparency, lawful processing, fairness, purpose limitation, data minimisation, accuracy, storage limitation, security, accountability, and respect for user rights. Where users access eDeafy from outside Nigeria, additional privacy rights may apply depending on their location. Where required by applicable law, we will take reasonable steps to honour such rights and apply appropriate safeguards for international data transfers.

Where there is a conflict between this Policy and mandatory applicable law, mandatory applicable law will prevail.

Information about disability status, deafness, hard-of-hearing status, accessibility needs, and communication preferences may be considered sensitive personal data in some jurisdictions.

We process sensitive personal data only where we have a lawful basis, such as your explicit consent, where necessary to provide accessibility services you request, where required by law, or where otherwise permitted by applicable data protection law.

You may update or withdraw optional accessibility preferences through your account settings where available or by contacting support@edeafy.com, subject to any data we must retain for legal, safety, operational, certificate, or recordkeeping purposes.

• directly from you when you register, create a profile, enroll, upload content, complete assessments, request support, or use platform features;
• automatically from your device and platform activity;
• from Trainers or Organisations that invite, enroll, sponsor, or manage learners;
• from payment processors, authentication providers, video hosting services, and other service providers;
• from authorised Admins who create or upload courses on behalf of Trainers or Organisations.

Depending on your location and the processing activity, we rely on one or more lawful bases, including:

• performance of a contract, such as creating accounts, delivering courses, tracking progress, issuing certificates, and providing paid services;
• consent, such as optional marketing, non-essential cookies, and certain sensitive accessibility preferences;
• legitimate interests, such as platform security, fraud prevention, service improvement, analytics, quality review, support, and operational administration, where not overridden by your rights;
• legal obligation, such as tax, accounting, dispute, fraud prevention, regulatory, and compliance obligations;
• vital interests or public interest where applicable in exceptional situations.

• create, verify, secure, and manage user Accounts;
• deliver sign-language-supported courses and learning features;
• track progress, module completion, quiz attempts, assessment scores, and certificates;
• provide learner dashboards, trainer dashboards, organisation dashboards, and admin dashboards;
• process payments, subscriptions, refunds, payouts, certificates, invoices, and receipts;
• review course submissions, run automated pre-checks, conduct human review, request changes, and publish approved courses;
• support accessibility preferences and recommend suitable content where appropriate;
• respond to support requests, complaints, disputes, and safety reports;
• send service messages, account notices, policy updates, receipts, course updates, and security alerts;
• send marketing communications only where permitted and with required opt-out controls;
• monitor, analyse, improve, secure, and troubleshoot the Platform;
• prevent fraud, abuse, security incidents, unauthorised access, cheating, and policy violations;
• comply with legal obligations and respond to lawful requests.

eDeafy may use automated tools to assist with course quality and compliance checks, such as identifying missing course fields, incomplete quiz answers, missing final assessments, long video durations, formatting issues, missing certificate settings, or inconsistent metadata.

Automated tools do not replace human review for sign language quality, accessibility suitability, video clarity, sensitive content, health-related content, cultural appropriateness, or final course approval.

Where an automated tool flags an issue, a Trainer or Organisation may receive a notice or correction request. eDeafy may allow human review of disputed automated flags where appropriate.

eDeafy uses role-based access controls and organisation-level separation to limit access to data. Organisations should only access learner data related to their own courses, programmes, dashboards, and authorised users.

Learner data from one Organisation should not be visible to another Organisation. Trainers and Organisations should not access unrelated learner accounts, payment card details, private accessibility data beyond what is necessary, or unrelated course activity.

We may use cookies, pixels, local storage, and similar technologies to operate, secure, improve, analyse, and personalise the Platform.

• Strictly necessary cookies help the Platform function, authenticate users, secure sessions, and prevent fraud.
• Functional cookies remember preferences such as language, accessibility settings, and account choices.
• Analytics cookies help us understand usage and improve performance.
• Marketing cookies, if used, support relevant communications and campaigns where permitted.

Where required by law, we will provide cookie controls that allow users to manage non-essential cookies. Withdrawing consent for non-essential cookies should not prevent use of core Platform features.

Because eDeafy may use cloud, payment, email, video, and technical service providers in different countries, personal data may be transferred to or processed in countries outside your country of residence.

Where required, we use appropriate safeguards such as contractual protections, data processing agreements, standard contractual clauses, security measures, and vendor due diligence. For Nigeria-related transfers, we aim to comply with the Nigeria Data Protection Act 2023 and applicable NDPC requirements. For users outside Nigeria, we will apply transfer safeguards required by applicable local law where such law applies to our processing activities.

We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law.

• Account data: retained while the Account is active and for a reasonable period after closure for legal, security, and support purposes.
• Course progress and certificate records: retained for a longer period where needed for certificate verification, learner records, organisation reporting, disputes, or legal obligations.
• Payment, tax, invoice, refund, and accounting records: retained as required by applicable tax, finance, accounting, and anti-fraud obligations.
• Support messages and complaints: retained as long as needed to resolve issues, improve services, and manage legal or safety risks.
• Marketing preferences: retained until opt-out, withdrawal, or deletion, plus a reasonable period to evidence compliance.
• Security logs: retained for a limited period unless needed for investigation, fraud prevention, legal claims, or security purposes.

When data is no longer required, we will delete, anonymise, or securely archive it according to our retention practices and legal obligations.

We implement appropriate technical and organisational measures designed to protect personal data from unauthorised access, loss, misuse, alteration, disclosure, or destruction.

Measures may include encryption in transit, access controls, role-based permissions, secure authentication, monitoring, backups, secure development practices, vendor safeguards, and incident response procedures. No system is perfectly secure, and we cannot guarantee absolute security.

If a data breach occurs and notification is required by law, we will notify affected users, regulators, or other parties within the legally required timelines.

The Platform is not intended for children under 13. We do not knowingly collect personal data from children under 13 without appropriate consent. If we learn that such data has been collected improperly, we will take reasonable steps to delete it.

Users under the age of majority may use the Platform only with parent or guardian consent and supervision. We may restrict access to certain courses, discussions, community features, or sensitive content for minors.

Parents or guardians may contact support@edeafy.com to request review, correction, or deletion of a minor account, subject to legal, safety, certificate, and operational obligations.

Depending on your location, you may have rights to:

• access the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of personal data, subject to legal and operational exceptions;
• restrict or object to certain processing;
• withdraw consent where processing is based on consent;
• request data portability where applicable;
• object to certain automated processing where applicable;
• lodge a complaint with a data protection authority.

To exercise rights, contact legal@edeafy.com or support@edeafy.com. We may need to verify your identity before acting on a request. We will respond within the timeframe required by applicable law.

We may send marketing communications only where permitted by law and where we have the required consent or lawful basis. You can opt out of marketing emails using the unsubscribe link or by contacting support@edeafy.com. You may still receive service-related messages such as receipts, security notices, course updates, policy updates, or account notices.

The Platform may contain links to third-party websites, embedded videos, payment processors, analytics tools, social sign-in services, or other third-party services. Their privacy practices are governed by their own policies. We are not responsible for third-party privacy practices except where required by law or contract.

eDeafy aims to make this Privacy Policy accessible. We may provide simplified summaries, downloadable versions, or sign-language-supported explanations of key privacy points as the Platform develops. If you need this Policy in an alternative accessible format, contact support@edeafy.com.

We may update this Privacy Policy from time to time to reflect changes in our practices, services, technology, legal requirements, or operational needs. We will update the effective date and, where required, provide additional notice or request renewed consent for material changes.

For privacy, legal, or data protection questions, please contact:

Data Controller and Privacy Team

eDeafy Platform Operators (Nigeria)

legal@edeafy.com