Excelmind

Effective Date: 01 July, 2025

This Privacy Policy (“Policy”) constitutes a binding agreement between ExcelMind (“ExcelMind”, “we”, “our”, “us”) and any natural person or legal entity (“User”, “you”, “your”) who accesses, registers for, or otherwise makes use of our platform, applications, or related services (collectively, the “Services”). By engaging with the Services, you acknowledge that you have read, understood, and accepted the terms of this Policy, and you consent to the collection, processing, storage, and transfer of your personal data as herein provided.

1. Definitions

Personal Data: Any information relating to an identified or identifiable natural person, including but not limited to names, contact details, student records, and digital identifiers.
Processing: Shall bear the meaning accorded under applicable data protection legislation, including but not limited to the General Data Protection Regulation (EU/UK GDPR) and the Nigeria Data Protection Regulation (NDPR).
Controller: Refers to the school, institution, or entity that determines the purposes and means of processing Student Data via the Services.
Processor: Refers to ExcelMind in its capacity of handling such Personal Data on behalf of Controllers.

2. Categories of Data Collected

Account Information: Names, email addresses, telephone numbers, school or institutional details, and authentication credentials.
Educational Records: Student enrollment data, attendance records, results, curricula, assessments, and related educational outputs.
Communication Data: Messages, notifications, inquiries, and support interactions between Users and the Services.
Technical Data: IP addresses, device identifiers, system logs, browser metadata, and usage analytics.
Financial/Billing Data: Payment identifiers and transaction records (collected and processed via secure third-party payment providers).

3. Purpose of Processing

To deliver, administer, and maintain the Services.
To fulfil contractual obligations towards schools, teachers, parents, and students.
To comply with statutory and regulatory requirements imposed by competent authorities.
To safeguard the security, integrity, and lawful use of the Services.
To enhance, optimise, and develop the Services through aggregated analytics.
To communicate with Users in respect of system updates, administrative matters, or lawful marketing (where consent is expressly obtained).

4. Lawful Basis for Processing

Performance of a Contract: Where Processing is necessary for the execution of subscription or service agreements with schools or Users.
Legal Obligation: Where Processing is mandated by applicable legislation or regulatory directive.
Legitimate Interest: Where Processing is required for the efficient operation, improvement, or protection of the Services, provided such interest does not override the fundamental rights and freedoms of the data subject.
Consent: Where Processing relates to optional activities (e.g., direct marketing or non-essential cookies).

5. Disclosure and Transfer of Data

To authorised administrators, teachers, or school representatives acting in the capacity of Controllers.
To duly engaged third-party service providers (including hosting providers, payment processors, and communication gateways), subject to binding data processing agreements.
To regulatory, governmental, or judicial authorities upon valid legal demand.
In the event of merger, acquisition, or corporate restructuring, subject to lawful safeguards.
Where Personal Data is transferred across jurisdictions, including transfers outside Nigeria or the United Kingdom, ExcelMind shall implement adequate safeguards such as Standard Contractual Clauses or equivalent mechanisms recognised under applicable law.

6. Data of Children and Minors

ExcelMind recognises the sensitive nature of student data, particularly data relating to minors. Such data shall be processed exclusively under the lawful authority of schools, institutions, or parents/guardians, and in strict accordance with COPPA (United States), GDPR provisions on children, and NDPR requirements. Direct registration by children below the age of thirteen (13) is prohibited.

7. Data Retention and Destruction

ExcelMind shall retain Personal Data strictly for the duration necessary to achieve the Processing purposes specified in this Policy and in compliance with statutory retention periods. Upon expiry of such periods, data shall be securely deleted, anonymised, or otherwise irreversibly destroyed, save where extended retention is mandated by law or contractual obligation.

8. Security Measures

ExcelMind shall employ technical and organisational measures consistent with industry standards to ensure the confidentiality, integrity, and availability of Personal Data, including but not limited to encryption in transit and at rest, role-based access controls, regular vulnerability testing, and staff confidentiality undertakings. Notwithstanding these measures, Users acknowledge that no system is immune from all potential security breaches, and ExcelMind disclaims liability for unauthorised access arising from factors beyond its reasonable control.

9. Rights of Data Subjects

Right of access to their Personal Data.
Right to rectification of inaccurate or incomplete data.
Right to erasure (“right to be forgotten”), subject to retention requirements.
Right to restriction or objection to Processing.
Right to data portability in a machine-readable format.
Right to withdraw consent at any time, without prejudice to the lawfulness of Processing prior to withdrawal.
Right to lodge a complaint with a competent data protection authority.

Requests may be submitted to the Data Protection Officer at the contact details provided in Section 11.

10. Liability and Indemnification

Users acknowledge that ExcelMind acts primarily as a Processor and that the responsibility for lawful collection and provision of student data lies with the Controller (i.e., the relevant school or institution). Accordingly, schools and institutions warrant that they have obtained all requisite parental or guardian consents and shall indemnify ExcelMind against any claims, penalties, or liabilities arising from unlawful or unauthorised provision of Personal Data.

11. Contact Information

Please send us an email at info@excelmind.org

12. Amendments

ExcelMind reserves the right to amend, update, or revise this Policy from time to time to reflect changes in law, technology, or business operations. Substantive modifications shall be notified to Users via prominent notice within the Services or via electronic communication. Continued use of the Services after such notice shall constitute acceptance of the revised Policy.