Empower Academy PVAC – Privacy Policy (Nigeria)

Empower Academy PVAC Platform, operated by Empower Swiss SARL and managed under Empower PVAC Academy, is committed to safeguarding the privacy and personal data of its users located in Nigeria. This Privacy Policy explains how we collect, use, disclose, and protect your personal information in compliance with the compliance with the Nigeria Data Protection Act, 2023 (NDPA) and directives issued by the Nigeria Data Protection Commission (NDPC), and other applicable Nigerian laws.

1. Scope

This Privacy Policy applies exclusively to users who access and use the Empower Academy PVAC website and services within the Federal Republic of Nigeria.

2. Information We Collect

When you register, log in, or interact with our Platform, we may collect the following categories of personal data:

• Full Name (First and Last)
• Email Address
• Password (encrypted)
• Designation, Organization
• Country, State, City/Town
• Learner Category and Sub-category
• Log data (IP address, browser type, device information)

We do not collect or store sensitive biometric or financial information.

3. Purpose of Data Collection

If you are in the EU/EEA/UK, Empower Swiss SARL is the controller. We rely on Art. 6 GDPR lawful bases as described above. Where we transfer your data to Nigeria or other non-EEA countries, we use Art. 46 GDPR safeguards (e.g., EU Standard Contractual Clauses) and conduct transfer risk assessments.

Empower Academy PVAC uses personal information solely for legitimate business and educational purposes, including:

• Providing access to online training programs
• User authentication and account management
• Generating and issuing training certificates
• Personalizing course recommendations and content
• Platform analytics and performance improvement
• Compliance with Nigerian regulatory requirements

4. Legal Basis for Processing Personal Data

Your personal data is processed under the following lawful bases as defined in the Nigeria Data Protection Act (NDPA) 2023:

• Consent: When you voluntarily register and agree to our Terms of Use.
• Contractual Necessity: To deliver learning and certification services.
• Legal Obligation: To comply with regulatory and educational reporting duties.
• Legitimate Interest: To maintain and improve our digital learning infrastructure.

5. Data Storage and Security

All data collected from Nigerian users is stored securely on servers with restricted access. Passwords are encrypted using industry-grade standards. We employ firewalls, SSL encryption, and access logs to prevent unauthorized data access, alteration, or disclosure.

If a personal data breach is likely to result in risk to individuals, we will notify the NDPC within 72 hours of becoming aware. If there is a high risk, we will notify affected individuals without undue delay.

6. Data Sharing and Third Parties

Empower does not sell, trade, or rent personal information. Data may be shared only with:

• Hosting & security providers.
• Learning analytics providers.
• E-mail/SMS delivery vendors.
• Certification/credentialing services.
• All are bound by written Data Processing Agreements.
• Authorized service providers under Data Processing Agreements (DPAs).
• Regulatory bodies, if required under Nigerian law.

All third-party processors are required to comply with NDPR/NDPA standards and maintain strict confidentiality.

7. Cookies & Similar Technologies

We use cookies for authentication, preferences, and analytics. You can manage non-essential cookies via our banner and settings page. See our Cookie Notice for purposes, lifespans, and providers.

8. International Data Transfer

We transfer personal data outside Nigeria only where adequate safeguards are in place (e.g., NDPC-approved Cross-Border Data Transfer Instrument or contractual clauses approved/recognised by NDPC). Where consent is relied upon or contractual necessity applies, we will also inform you of the safeguards used.

9. User Rights (Under NDPA 2023)

As a data subject in Nigeria, you have the following rights:

• Right to Access: Obtain a copy of your personal data.
• Right to Rectification: Request correction of inaccurate or incomplete information.
• Right to Erasure: Request deletion of your personal data when no longer needed.
• Right to Withdraw Consent: Withdraw consent for processing at any time.
• Right to Data Portability: Request transfer of your data to another platform.
• Right to Object: Restrict or object to specific processing activities.
• Right to Lodge a Complaint: File a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your rights have been violated.
• Submit requests via [email protected].We respond promptly (and within one month where GDPR applies). You may escalate to the NDPC if dissatisfied: ndpc.gov.ng

10. User Responsibilities

As a registered user of the Empower Academy PVAC Platform, you are responsible for:

• Providing accurate and up-to-date registration details.
• Maintaining the confidentiality of your login credentials.
• Immediately reporting any unauthorized access to your account.
• Using the platform only for lawful educational purposes in Nigeria.

11. Data Retention

Account data: retained for your active use and 1 years after last activity or course completion (for certificate verification). We retain personal data only for as long as necessary to fulfill the purposes outlined in this Policy or as required by Nigerian law. After expiration or account deletion, data will be securely anonymized or destroyed.

• Certificate records: 2 years to meet verification/legal requirements
• Logs/IP: 12 months for security/fraud prevention.
• We will anonymise or delete after these periods.

12. Children’s Privacy

The Platform is designed for individuals aged 18 years and above. We do not knowingly collect personal data from minors. Parents or guardians who believe their child has provided information may contact us to request deletion.

13. Changes to This Privacy Policy

Empower Academy PVAC reserves the right to modify or update this Privacy Policy at any time. In case of significant changes, users will be notified via:

• Email communication, or
• Notice displayed on the platform homepage.

14. Contact Information

For inquiries, complaints, or data protection requests, please contact:

• Email: [email protected]