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Sign in to manage your data1. Who we are
Acme Hub Limited (RC: 9735410) is a company incorporated under the laws of the Federal Republic of Nigeria, with its registered address at Block 19A, Phase 2, Federal Housing Authority, Karu, FCT, Nigeria.
We act as the Data Controller for the personal data collected and processed through our educational platform. For all data protection enquiries, clarifications, or to exercise your rights, please contact our Data Protection team at acmelanguagehub@gmail.com.
2. Personal data we collect
We collect personal data that you provide directly to us, data generated automatically through your use of the Platform, and data received from trusted third parties.
2.1 Information you provide directly
- Identity Data: Full name, date of birth (where required for official exam validation or certification purposes), and gender.
- Contact Data: Email address, telephone number, and residential or mailing address.
- Account Data: Username, account preferences, and secure login credentials.
- Educational Data: IELTS mock test scores, practice test responses, coaching progress logs, feedback, and written or audio correspondence with tutors and support staff.
- Communications Data: Records of correspondence when you contact customer support, including support tickets, emails, and live chat histories.
2.2 Information collected automatically
- Technical Data: Internet Protocol (IP) address, browser type and version, device hardware identifiers, operating system, and time zone settings.
- Usage Data: Pages viewed, duration of visit, course modules accessed, navigation paths (click-stream data), and account login history.
- Tracking Data: Information gathered via cookies and similar web tracking technologies (see Section 9).
2.3 Information from third parties
- Payment Transaction Data: Payment status confirmations received from our licensed payment processor, Paystack Payments Limited. We do not store your raw credit/debit card numbers on our servers.
- Analytics Data: Information from market research and web analytics providers.
- Social Media Integrations: Profile details shared with us if you choose to link, log in, or interact with our platform via third-party social media authentication systems.
3. Why we process your personal data
We process your personal data for specific, lawful purposes in order to deliver our services and fulfill our contractual commitments:
- Educational Service Delivery: To manage your account creation, enroll you in courses, grant access to training materials, host live classes, track course progress, administer evaluations, score mock assessments, and issue official certificates.
- Operational Communications: To send automated administrative updates, account alerts, technical reminders, academic schedules, responses to customer support queries, and notices of material updates to our services.
- Marketing and Growth: To distribute promotional newsletters, course updates, and special offers where permitted by law, subject to your explicit right to opt out at any time.
4. Legal basis for processing
In strict compliance with Section 25 of the Nigeria Data Protection Act (NDPA) 2023, we only process personal data when an appropriate legal basis exists.
| Purpose of processing | Categories of personal data | Legal basis (NDPA 2023) | Third parties involved |
|---|---|---|---|
| Account creation & verification | Full name, email, phone, hashed password | Performance of a contract | None |
| IELTS coaching & progress tracking | Course activity, mock scores, educational logs | Performance of a contract | None |
| Payment & fee processing | Name, email, billing address, transaction refs | Contract / legal obligation | Paystack Payments Limited |
| Customer support & inquiries | Name, email, phone number, ticket history | Contract / legitimate interests | Helpdesk/CRM software vendors |
| Marketing communications | Name, email address, preferences | Consent (opt-in) | Email & SMS marketing platforms |
| Platform optimization & security | IP address, device strings, cookie details | Legitimate interests | Web analytics providers |
| Regulatory & legal compliance | Identity data, financial transaction logs | Compliance with a legal obligation | Law enforcement, NDPC, tax authorities |
5. Marketing communications and your opt-out rights
Where we rely on your consent to transmit promotional materials, you maintain an absolute right to withdraw that consent at any time. You may unsubscribe by:
- Clicking the "Unsubscribe" hyperlink embedded at the footer of our marketing emails.
- Modifying your notification parameters inside your account settings dashboard.
Withdrawing consent does not retroactively impact the lawfulness of processing handled prior to the withdrawal. We will continue to transmit transactional, academic, or security alerts necessary to administer your active account.
6. Disclosure of your personal data
We do not sell, rent, or trade your personal data. We disclose information to trusted service providers only to the extent necessary to perform their specialized tasks under strict data processing agreements:
- Payment Processing: Paystack Payments Limited, to securely process tuition and course fees under CBN payment regulations.
- Infrastructure Hosting: Cloud providers and IT infrastructure data centers to securely host platform code and databases.
- Communications: Specialized SMS and email gateways utilized to deliver system notifications and marketing materials.
- Professional Advisors: Legal counselors, auditors, and accountants as required to manage corporate compliance.
- Legal Mandates: Law enforcement, courts, or regulatory commissions (such as the NDPC) if we are legally obligated to prevent fraud, protect safety, or comply with an ongoing investigation.
7. International transfers of personal data
Because we utilize global cloud hosting, IT infrastructure, and international software utilities, your personal data may occasionally be transferred to, stored in, or processed in jurisdictions outside of Nigeria.
Whenever such international transfers occur, Acme Hub Limited ensures full compliance with Chapter V of the NDPA 2023. We confirm that the recipient country maintains an adequate level of data protection laws, or we implement Standard Contractual Clauses (SCCs) and binding agreements to guarantee your data remains protected to the same high standards required within Nigeria.
8. Data retention policy
We retain your personal data only for as long as is strictly necessary to fulfill the operational purposes detailed in this policy, satisfy legal or tax requirements, resolve corporate disputes, and enforce our contracts.
- Account & Educational Records: Retained for the duration of your active relationship with our Platform, plus a reasonable window thereafter should you choose to reactivate your profile.
- Financial Transaction Records: Preserved in accordance with statutory timelines dictated by Nigerian financial and anti-money laundering regulations.
When personal data is no longer tied to a valid retention requirement, it is either permanently purged from our infrastructure or scrubbed of all identifying markers via irreversible anonymization protocols.
9. Cookies and tracking technologies
Our platform uses cookies — small string data files saved onto your browser — to optimize your system navigation. We utilize two primary tiers:
- Strictly Necessary Cookies: Essential web mechanisms required to support login authentication, secure payment sessions, and prevent cross-site scripting vulnerabilities. Disabling these via your browser settings will break core platform capabilities.
- Preference & Analytics Cookies: Optional cookies that remember choices (such as preferred display theme) and help us evaluate web performance via aggregated visitor metrics.
You can control, adjust, or block non-essential tracking mechanisms at any time through your local web browser settings.
10. Your data subject rights
Under the Nigeria Data Protection Act (NDPA) 2023, you hold explicit, legally enforceable rights regarding your personal data. You may invoke any of these rights free of charge by emailing us at acmelanguagehub@gmail.com:
| Right | What it means |
|---|---|
| Right of access | Request absolute confirmation on whether we process your data, alongside an authorized copy of that specific dataset. |
| Right to rectification | Request immediate fixes to inaccurate, outdated, or incomplete elements of your personal records. |
| Right to erasure | Request the total deletion of your files where there is no longer a valid legal grounding for us to keep them. |
| Right to restrict processing | Limit how we process your information under specific conditions (e.g., if you are disputing accuracy). |
| Right to data portability | Obtain your data in a structured, clean, machine-readable format to move seamlessly to another vendor. |
| Right to object | Halt processing operations grounded specifically on corporate "legitimate interests" or direct marketing outreach. |
| Right to withdraw consent | Cancel processing permissions you previously granted us without affecting the legality of past data uses. |
| Right to lodge a complaint | File an official grievance with the regulatory authority, the Nigeria Data Protection Commission (NDPC). |
11. Security and breach notification frameworks
We deploy robust technical and organizational security controls to shield your personal profiles from malicious leaks, alteration, access, or destruction. These safeguards consist of:
- Full Transport Layer Security (TLS/SSL) encryption for data in transit and robust encryption standards for information at rest.
- Granular access control permissions, ensuring only vital personnel with a strict "need-to-know" clearance can interact with customer records.
- Ongoing vulnerability patch cycles, secure storage configurations, and routine system evaluations.
- Formalized incident response playbooks and data protection training for all personnel.
In strict alignment with the NDPA 2023, should a systemic data breach occur that threatens your personal rights and freedoms, we commit to notifying the Nigeria Data Protection Commission (NDPC) within 72 hours of discovery, and we will notify affected users directly without undue delay.
12. Changes to this Privacy Policy
We reserve the right to modify this document at our discretion to accommodate new learning services, system updates, or legislative changes in Nigeria.
If modifications are material, we will provide a prominent notice across our platform dashboard or dispatch an email alert directly to your inbox before the updates go live. The "Last Updated" timestamp at the top of this page reflects our most recent review.