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Privacy Policy

Last updated: January 2025 Β· Effective: January 2025

Your privacy is important to us. This Privacy Policy explains how GSBS Solutions Ltd collects, uses, stores, and protects your personal data when you use the GSBS Digital Tutor platform.

1. Introduction

GSBS Solutions Ltd ('we', 'our', 'us') operates the GSBS Digital Tutor platform. We are committed to protecting the personal data of all users, particularly those of children. This Privacy Policy explains what data we collect, how we use it, and the rights you have regarding your personal information.

2. Data We Collect

When you register and use the Platform, we collect the following categories of personal data: (a) Account Information β€” full name, email address, class grade, preferred language, user role, and plan type; (b) Learning Data β€” lessons completed, quiz scores, time spent on lessons, assignment results, and exam practice results; (c) Usage Data β€” pages visited, features used, session duration, and interaction patterns; (d) Device & Technical Data β€” browser type, operating system, IP address, and device type, collected for security and performance purposes. We do not directly collect payment card numbers. All subscription payments are processed by third-party payment providers.

3. How We Use Your Data

Your personal data is used for the following purposes: (a) Learning Personalisation β€” to tailor lesson content, quiz difficulty, and assignments to each student's grade level and performance; (b) Progress Tracking β€” to record completed lessons and generate progress reports accessible to students and, under the Family Plan, to parents; (c) Platform Improvement β€” to improve lesson quality, identify learning gaps, and develop new features based on aggregate usage patterns; (d) Parent Monitoring β€” to provide Family Plan subscribers with a parent dashboard showing each child's activity and progress; (e) Account Management β€” to manage subscriptions, send transactional notifications, and respond to support queries; (f) Legal Compliance β€” to meet obligations under applicable Nigerian law.

4. No Selling of Data

GSBS Solutions Ltd does not sell, rent, or trade your personal data to any third party for commercial purposes. We do not use student data for advertising purposes. We do not allow third-party advertisers to access student data.

5. Data Sharing with Service Providers

We share your data only with trusted service providers who process it on our behalf under strict data protection agreements. These providers are: Supabase (database hosting and storage β€” all data is encrypted at rest and in transit); Clerk (user authentication and identity management); Upstash (performance caching β€” no personally identifiable information is stored in the cache beyond session data); Cloudflare R2 (media and video storage for lesson content); Digital tutoring response providers (Groq, Google Gemini, OpenRouter β€” user messages are sent solely to generate lesson-relevant responses, and no personal data is stored by these providers beyond the session). All providers are contractually required to comply with applicable data protection standards.

6. Children's Privacy

We take the privacy of children very seriously. For users under the age of 13, parental or guardian consent is required before an account can be created. Parents and guardians may, at any time: (a) request full access to their child's account data; (b) request correction of inaccurate data; (c) request deletion of their child's account and all associated data; (d) withdraw consent for data processing. Requests must be submitted to privacy@gsbstutor.com with appropriate verification.

7. Secure Storage

All personal data is stored securely using Supabase, a PostgreSQL-based database platform with encryption at rest (AES-256) and encryption in transit (TLS 1.2+). Access to the database is restricted to authorised personnel only. Authentication is managed by Clerk, which implements industry-standard security measures including two-factor authentication options. We conduct regular security reviews and apply patches promptly.

8. Data Retention

We retain your account and learning data for as long as your account remains active. If you close your account, your personal data will be deleted within 30 days, except where we are legally required to retain it for a longer period. Aggregate, anonymised usage data (which cannot be linked to you personally) may be retained indefinitely for platform improvement purposes.

9. Cookies and Tracking

The Platform uses strictly necessary cookies for session management and authentication. We do not use advertising cookies, tracking pixels, or analytics tools that share data with third-party advertising networks. You may disable cookies in your browser settings, but doing so may affect the functionality of the Platform.

10. Your Rights

You have the following rights with respect to your personal data: (a) Right of Access β€” to request a copy of the personal data we hold about you; (b) Right to Rectification β€” to request correction of inaccurate or incomplete data; (c) Right to Erasure β€” to request deletion of your data under certain circumstances; (d) Right to Restriction β€” to request that we restrict the processing of your data; (e) Right to Data Portability β€” to receive your data in a machine-readable format; (f) Right to Withdraw Consent β€” to withdraw consent for any processing based on consent. To exercise any of these rights, contact us at privacy@gsbstutor.com.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the 'Last updated' date above and notify registered users via email where the changes are material. Continued use of the Platform after such notification constitutes acceptance of the revised policy.

12. Contact

Data Controller: GSBS Solutions Ltd | Privacy Officer Email: privacy@gsbstutor.com | General Support: support@gsbstutor.com | Country: Nigeria

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GSBS Digital Tutor β€” Nigeria's Digital Tutor