Effective September 1, 2023

PRIVACY POLICY 

This Privacy policy issued by UPSKILLING TECHNOLOGIES LTD constitutes our commitment to your privacy on our administrative records, websites, social media platforms and premises.

1.0 Your Privacy Rights

1.1 This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information. It applies to the UPSKILLING website and all database, applications, services, tools and physical contact with us, regardless of how you access or use them.

1.2 If you have created a username, identification code, password or any other piece of information as part of our access security measures, you must treat such information as confidential, and you must not disclose it to any third party.

1.3 We reserve the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of this privacy policy.

1.4 You reserve the rights upon request to delete, change, correct, limit or restrict the use of your personal information as well as request for a readable copy of all your personal information you provided. All requests and complaints should be channeled to …. and will be acknowledged and resolved within 45 days.

1.4 If you know or suspect that anyone other than you knows your security details, you must promptly notify us at compliance@upskillingcareers.com

2.0 Consent 

You accept this privacy policy when you give consent upon access to our platforms, or use our services, content, features, technologies or functions offered on our website, digital platforms or visit any of our offices for official or non-official purposes (collectively the “UPSKILLING Services”). This privacy policy governs the use of the UPSKILLING Services unless otherwise agreed through a written contract. We may amend this privacy policy at any time by posting a revised version on our website, or placing such notice at conspicuous points at our office facilities. The revised version will be effective 7 days after publication.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

3.0 Your Personal Information

3.1 When you use the UPSKILLING Services, we collect information sent to us by your computer, mobile phone or other electronic access device. The automatically collected information includes but is not limited to data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, standard web log data, still and moving images.

3.2 We may also collect information you provide us including but not limited to information on web form, survey responses, account update information, email address, phone number, organization you represent, official position, correspondence with the UPSKILLING support services, and telecommunication with the UPSKILLING. We may also collect information about your transactions, enquiries and your activities on our platform or premises.

3.3 We may also use information provided by third parties like social media sites. Information about you provided by other sites is not controlled by UPSKILLING and we are, therefore, not liable for how such third parties use your information.

4.0 What we do with your personal information 

The purpose of collecting your personal information is to give you efficient, enjoyable and secure service. We may use your information to:

1. Provide UPSKILLING Services and support;

2. Process applications and send notices about your transactions to requisite parties;

3. Verify your identity;

4. Resolve disputes, collect fees, and troubleshoot problems;

5. Manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;

6. Detect, prevent or remediate violation of laws, regulations, standards, guidelines and frameworks;

7. Improve UPSKILLING Services by implementing aggregate customer or user preferences;

8. Measure the performance of UPSKILLING Services and improve content, technology and layout;

9. Track information breach and remediate such identified breaches;

10. Manage and protect our information technology and physical infrastructure; or

11. Contact you at any time through your provided telephone number, email address or other contact details.

5.0 Cookies 

Cookies are small files placed on your computer’s hard drive that enables the website to identify your computer as you view different pages. Cookies allow websites and applications to store your preferences in order to present contents, options or functions that are specific to you. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user.

You have choices to limit collection of browsing information through cookies and trackers. You can limit the automatic collection of information by any participating third-party advertisers, including the collection of personally identifiable information about an individual's online activities over time and across third-party websites or online services, by opting-out of such collection.

6.0 How we protect your personal information 

We store and process your personal information on our computers in Nigeria. Where we need to transfer your data to another country, such a country must have an adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.

7.0 How We Share your information within UPSKILLING TECHNOLOGIES LTD and with Other Users

7.1 Your personal information is regarded as highly confidential and is handled with utmost care by our team of professionals. We have a tight network loop for processing all your personal information. 

7.2 We work with third parties to perform UPSKILLING Services and implement its mandate. In doing so, a third party may share information about you with us, such as your email address or mobile phone number.

7.3 You accept that your pictures and testimonials on all social media platforms about UPSKILLING can be used for limited promotional purposes by us. This does not include your trademark or copyrighted materials.

7.4 From time to time we may send you relevant information such as news items, enforcement notice, statutorily mandated notices and essential information to aid the implementation of our mandate. We may also share your personal information in compliance with national or international laws; crime prevention and risk management agencies and service providers.

8.0 Security

8.1 We will always hold your information securely. To prevent unauthorized access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. Our website uses Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your Personal Data. You should see the padlock symbol in your URL address bar once you are successfully logged into the platform. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission.

Please note that no electronic transmission, storage, or processing of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will always be sufficient or effective. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your personal information will always remain private or secure.

You understand and acknowledge that you assume all responsibility and risk for your use of our websites and apps, the internet generally, and the documents you post or access, and for your conduct on and off our websites. To further protect yourself, you should safeguard your UPSKILLING account username and password by refraining from sharing that information with anyone. You should also sign off your account and close your browser window when you have finished your visit to our websites. Please note that we will never ask for your UPSKILLING account username or password via email.

8.2 UPSKILLING has also taken measures to comply with global Information Security Management Systems. We, have, therefore, put in place digital and physical security measures to limit or eliminate possibilities of data privacy breach incidents.

9.0 Data Confidentiality Rights

Your information is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions. You have the right to request sight of, and copies of any and all information we keep on you, if such requests are made in compliance with the Freedom of Information Act and other relevant enactments. While UPSKILLING is responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our premises, dealing with only authorized officers of the Agency.

10.0 Links to Other Websites and Premises

10.1 Certain transaction processing channels may require links to other websites or organizations other than ours. Please note that the UPSKILLING is not responsible and has no control over websites outside its domain. We do not monitor or review the content of other party’s websites which are linked from our website or media platforms.

10.2 Opinions expressed or materials appearing on such websites are not necessarily shared or endorsed by us, and the UPSKILLING should not be regarded as the publisher of such opinions or materials.

10.3 Please be aware that we are not responsible for the privacy practices, or content of these sites.

10.4 We encourage our users to be aware of when they leave our site, and to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site yourself, before disclosing any personal information to them.

10.5 UPSKILLING will not accept any responsibility for any loss or damage in whatever manner, however caused, resulting from your disclosure to third parties of personal information. 

11.0 Children's Privacy Rights

We do not knowingly collect, maintain, or sell information from anyone under the age of 16. If you are under 16, please do not use our websites or mobile apps. In the event that we learn that we have collected personal information from a child under the age of 16, we will delete that information as quickly as possible.

12.0 Governing Law 

This privacy policy is made pursuant to the Nigeria Data Protection Regulation 2019 and other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.