Legal
Privacy Policy
Last Updated: [TO COMPLETE: Date of Publication]
1. Introduction
Welcome to AfricaConnectHub ("AfricaConnectHub," "we," "us," or "our"), a learning management system ("Platform" or "Service") that connects learners and instructors across Africa and internationally. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you use our website, mobile applications, and related services (collectively, the "Service").
By creating an account or otherwise using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this policy, please do not use the Service.
This policy applies to:
- Learners who register for and take courses on AfricaConnectHub
- Instructors who create, upload, and sell courses on AfricaConnectHub
- Parents/Guardians of learners under the age of majority
- Visitors who browse the Platform without creating an account
Summary: We collect your information to create and manage accounts, deliver courses, process payments and payouts, support instructors and learners, improve the Platform, and keep the Service secure.
We do not sell your personal information.
You can request access, correction, deletion, restriction, portability, or withdrawal of consent by contacting TO COMPLETE: official privacy email.
Some data may be shared with trusted service providers such as payment processors, hosting providers, analytics tools, email tools, and support tools, only where necessary to operate the Service.
2. Who We Are (Data Controller Information)
AfricaConnectHub is operated by:
| Field | Details |
|---|---|
| Company/Entity Name | AfricaConnectHub [TO COMPLETE: full legal entity name if different] |
| Country of Registration | Switzerland |
| Registered Address | [TO COMPLETE: full registered address] |
| Company Registration Number | [TO COMPLETE: registration number, if applicable] |
| Contact Email (Privacy) | [TO COMPLETE: privacy@africaconnecthub.com] |
| General Contact Email | info@africaconnecthub.com |
| Data Protection Officer | [TO COMPLETE: name, role, or state not appointed] |
If you are located in Nigeria, South Africa, Switzerland, the EU/UK, Kenya, or another jurisdiction with its own data protection authority, see Section 16 for the relevant regulator to contact if we cannot resolve your concern directly.
3. Information We Collect
We collect the following categories of information:
3.1 Information You Provide Directly
| Category | Examples |
|---|---|
| Account & Profile Data | Full name, email address, phone number, username, password (hashed), profile photo, country/region, date of birth, language preference |
| Identity Verification Data | Government-issued ID or other verification documents (only if required for instructor onboarding, payouts, or fraud prevention) |
| Payment & Payout Data | Billing name, billing address, transaction history, instructor payout details. We do not store your full card number, CVV, or card expiry date — these are processed directly by our payment processor, Stripe. |
| Course Content | Course materials, videos, quizzes, assignments instructors upload; assignments, essays, quiz answers, and projects learners submit |
| Communications | Messages sent through in-platform messaging, discussion forums, support tickets, course Q&A, and reviews/ratings |
| Certificates & Credentials | Name and course completion data used to generate certificates of completion |
| Parental Consent Data | Parent/guardian name, email, and consent confirmation (where the learner is a minor) |
3.2 Information Collected Automatically
| Category | Examples |
|---|---|
| Device & Technical Data | IP address, browser type, operating system, device identifiers, device type |
| Usage Data | Pages visited, courses viewed, time spent on lessons, quiz attempts/scores, login timestamps, click patterns |
| Cookies & Similar Technologies | See Section 8 |
| Approximate Location Data | Derived from IP address (country/city-level, not precise GPS unless separately authorized) |
3.3 Information from Third Parties
- Information from payment processors (Stripe, Payoneer) confirming transaction status
- Information from single sign-on providers if you register/log in via Google or similar services
- Information from analytics or marketing partners (see Section 10)
3.4 Sensitive / Special Category Data
We do not intentionally collect sensitive categories of data (e.g., health information, religious beliefs, biometric data, racial or ethnic origin) unless you voluntarily provide it or it is strictly necessary for a specific course. Where such data is collected, we apply additional safeguards and seek your explicit consent.
4. How We Collect Information
We collect information when you:
- Register for an account or complete your profile
- Enroll in, purchase, or complete a course
- Upload course content as an instructor
- Communicate with us, instructors, or other learners
- Make a payment or receive a payout
- Interact with our website/app (automatically, via cookies and similar technology)
- Contact our support team
5. Legal Basis for Processing Your Data
We process personal data only where we have a valid legal basis, including:
- Consent: e.g., marketing emails, optional cookies, processing a minor's data with parental consent
- Performance of a Contract: e.g., creating your account, processing your course purchase, paying instructors
- Legal Obligation: e.g., tax record-keeping, responding to lawful regulatory requests
- Legitimate Interests: e.g., fraud prevention, platform security, improving the Service
| Processing Purpose | Legal Basis |
|---|---|
| Create and manage user accounts | Performance of a contract |
| Provide access to courses and track progress | Performance of a contract |
| Process course purchases and refunds | Performance of a contract / legal obligation |
| Process instructor payouts | Performance of a contract / legal obligation |
| Issue certificates and keep completion records | Performance of a contract / legitimate interests |
| Send marketing emails or newsletters | Consent |
| Use analytics cookies or tracking tools | Consent where required by law |
| Maintain platform security and prevent fraud | Legitimate interests / legal obligation |
| Respond to legal requests and keep accounting records | Legal obligation |
| Provide customer support | Performance of a contract / legitimate interests |
6. How We Use Your Information
We use the information we collect to:
- Create and manage your learner or instructor account
- Deliver course content, track progress, and issue certificates
- Process payments for courses/memberships and process instructor payouts
- Communicate with you about your account, courses, or transactions
- Provide customer support
- Personalize your learning experience (e.g., course recommendations)
- Detect, prevent, and investigate fraud, abuse, or security incidents
- Comply with legal and regulatory obligations (tax, accounting, law enforcement requests)
- Improve and develop the Platform, including via aggregated/anonymized analytics
- Send you marketing communications, where you have opted in (you may opt out at any time; see Section 17)
We do not use automated decision-making or profiling that produces legal or similarly significant effects on you without human oversight.
7. Children's Privacy and Minors on the Platform
AfricaConnectHub permits use by minors in recognition of its role as an educational platform, subject to the following safeguards:
- Parental/Guardian Consent: Where a learner is below the age of digital consent in their jurisdiction, we require verifiable consent from a parent or legal guardian before creating an account or processing the minor's personal data.
- Minimal Data Collection: We collect only the data strictly necessary to provide the educational service to minors.
- No Targeted Advertising to Minors: We do not use minors' data for targeted advertising or sell/share it with third parties for marketing purposes.
- Parental Rights: Parents/guardians may review, correct, or request deletion of their child's data at any time by contacting TO COMPLETE: official privacy email.
- Child-Friendly Notices: Where required (e.g., under NDPA), we provide simplified, age-appropriate explanations of data practices.
If we learn that we have collected personal data from a minor without appropriate consent, we will take steps to delete that information promptly.
8. Cookies and Tracking Technologies
We use cookies and similar technologies (web beacons, local storage, SDKs) to:
- Keep you logged in and remember your preferences
- Understand how learners and instructors use the Platform
- Measure and improve course performance and platform reliability
- Support optional marketing/analytics features (only with consent, where required by law)
| Cookie Type | Purpose | Consent Required? |
|---|---|---|
| Strictly Necessary | Login, security, account access, shopping cart, course access | No — strictly necessary |
| Functional | Language preference, video playback settings, user preferences | Depends on jurisdiction |
| Analytics | Understand page visits, course usage, performance and traffic sources | Yes where required by law |
| Marketing | Advertising, retargeting, campaign measurement, social media pixels | Yes before activation where required by law |
You can manage cookie preferences through our cookie consent banner and your browser settings. Disabling non-essential cookies will not prevent you from using core Platform features.
9. Payment Processing
AfricaConnectHub uses the following third-party payment infrastructure:
- Stripe: processes learner payments for course purchases and memberships. Stripe receives and stores your full payment card details directly; AfricaConnectHub does not store your complete card number, CVV, or expiry date on its own servers.
- Payoneer: used to process payouts to instructors. Instructors provide bank account or Payoneer account details, which are shared with Payoneer to facilitate payment.
We retain only transaction metadata necessary for accounting, tax compliance, dispute resolution, and customer support (e.g., amount, date, last 4 digits of card, transaction ID), not full payment credentials.
10. How We Share Your Information
We do not sell your personal information. We may share information with:
- Service Providers/Processors: cloud hosting providers, payment processors, email/communication tools, analytics providers, and customer support tools, bound by contractual confidentiality and data protection obligations
- Instructors: limited learner data (e.g., name, progress, submitted work) necessary for instructors to deliver and grade their own courses
- Other Learners: information you choose to share publicly, such as forum posts, reviews, or a public profile
- Legal and Regulatory Authorities: where required by law, court order, or to protect the rights, safety, or property of AfricaConnectHub, our users, or the public
- Business Transfers: in connection with a merger, acquisition, or sale of assets, subject to confidentiality commitments and notice to affected users where required
| Provider | Purpose | Data Shared | Status |
|---|---|---|---|
| Stripe | Learner payments, refunds | Billing and transaction data | TO COMPLETE |
| Payoneer | Instructor payouts | Payout account details, identity/tax data | TO COMPLETE |
| Hosting provider | Website and platform hosting | Account, usage, technical, course and platform data | TO COMPLETE |
| Email provider | Transactional emails, newsletters | Name, email address, notification preferences | TO COMPLETE |
| Analytics provider | Website and platform analytics | IP address, usage data, device data, cookie identifiers | TO COMPLETE |
| Customer support tool | Support tickets and user assistance | Contact details, messages, account support context | TO COMPLETE |
11. International Data Transfers
Because AfricaConnectHub serves learners and instructors across multiple African countries and internationally, your data may be transferred to and processed in countries other than your own, including countries where our hosting and payment providers operate.
Where we transfer personal data across borders, we take steps required under applicable law, including:
- NDPA (Nigeria): ensuring the receiving country/organization has adequate data protection safeguards, or relying on contractual protections
- POPIA (South Africa): ensuring the recipient is subject to laws, binding corporate rules, or contractual provisions that uphold POPIA-equivalent protections
- GDPR / UK GDPR: relying on adequacy decisions, Standard Contractual Clauses (SCCs), or another approved transfer mechanism
- Swiss FADP: where personal data is disclosed or made accessible abroad, we take appropriate steps to ensure that the destination country or recipient provides adequate data protection or that another permitted safeguard applies
12. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes outlined in this policy, including:
- Active accounts: for as long as your account remains active
- After account closure: [TO COMPLETE: up to 24 months or another final period] to comply with legal, tax, and accounting obligations
- Course completion records/certificates: retained indefinitely unless you request deletion
- Marketing data: until you withdraw consent or opt out
| Data Category | Retention Approach |
|---|---|
| Account data | Active + [TO COMPLETE] after closure |
| Payment, tax and accounting records | [TO COMPLETE: applicable tax/accounting law period] |
| Instructor payout records | [TO COMPLETE: payout, tax and accounting obligations] |
| Course progress and certificates | Retained to verify completion unless deletion requested |
| Marketing consent records | Until consent withdrawn, plus [TO COMPLETE: proof period] |
| Support tickets | [TO COMPLETE: e.g., 24 months after closure] |
| Security logs | [TO COMPLETE: e.g., 6–12 months unless needed for investigation] |
| Backups | [TO COMPLETE: backup retention cycle] |
13. Your Privacy Rights
Depending on your location, you have rights that may include:
- Right to be informed about how your data is processed (this policy)
- Right of access: request a copy of the personal data we hold about you
- Right to rectification: correct inaccurate or incomplete data
- Right to erasure/deletion: request deletion of your data, subject to legal retention requirements
- Right to restrict or object to processing: including objecting to direct marketing
- Right to data portability: receive your data in a structured, machine-readable format
- Right to withdraw consent at any time, where processing is based on consent
- Right to lodge a complaint with your local data protection authority (see Section 16)
To exercise any of these rights, contact us at TO COMPLETE: official privacy email. We will respond within the timeframe required by applicable law (commonly 30 days).
14. Data Security
We implement technical and organizational measures designed to protect your personal information, including:
- Encryption of data in transit (HTTPS/TLS) and, where appropriate, at rest
- Access controls limiting employee/staff access to personal data on a need-to-know basis
- Regular security reviews and monitoring for unauthorized access
- Secure, PCI-DSS-compliant payment processing through Stripe (we do not store full card data ourselves)
No method of transmission or storage is 100% secure. In the event of a data breach affecting your personal information, we will notify affected users and relevant regulators as required by applicable law.
15. Instructor-Specific Data Practices
Instructors on AfricaConnectHub additionally acknowledge that:
- We collect payout-related information (bank/Payoneer account details, tax identification information where required) to facilitate payment for course sales
- We may collect tax-related documentation as required by your country's tax authority or ours
- Course performance data (enrollments, revenue, learner engagement/completion rates) is shared with instructors for their own courses only
- Instructors are independently responsible for ensuring any learner data they access through the Platform is used solely for legitimate instructional purposes and not retained or used beyond what is necessary
16. Country-Specific Provisions and Regulatory Contacts
| Jurisdiction | Law | Regulator | Notes |
|---|---|---|---|
| Switzerland | Swiss FADP | Federal Data Protection and Information Commissioner (FDPIC) | Primary country; cross-border disclosure and transparency duties apply |
| Nigeria | Nigeria Data Protection Act, 2023 (NDPA) | Nigeria Data Protection Commission (NDPC) | Cross-border transfer restrictions apply; children defined as under 13 |
| South Africa | Protection of Personal Information Act (POPIA) | Information Regulator of South Africa | Children defined as under 18; opt-in consent required for marketing/cookies |
| EU/UK | GDPR / UK GDPR | Relevant national DPA / ICO (UK) | Standard Contractual Clauses used for transfers outside the EU/UK |
| Kenya | Data Protection Act, 2019 | Office of the Data Protection Commissioner (ODPC) | Similar consent and rights framework to GDPR |
| Other jurisdictions | Local data protection law | Local data protection authority | We aim to comply with applicable local law; contact us with jurisdiction-specific questions |
If you believe we have not adequately addressed a privacy concern, you have the right to lodge a complaint with your local data protection authority.
17. Marketing Communications
If you have opted in to receive marketing emails or notifications, you may withdraw consent at any time by:
- Clicking "unsubscribe" in any marketing email
- Updating your notification preferences in your account settings
- Emailing TO COMPLETE: official privacy email
We will continue to send essential service-related communications (e.g., payment confirmations, security alerts) even if you opt out of marketing.
18. Third-Party Links
The Platform may contain links to third-party websites or services (e.g., payment providers, social media, external course resources). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies separately.
19. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will notify you of material changes via email or a prominent notice on the Platform before the changes take effect. The "Last Updated" date at the top of this policy indicates when it was last revised.
20. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:
| Contact Field | Details |
|---|---|
| AfricaConnectHub Privacy Email | [TO COMPLETE: official privacy email] |
| General Email | info@africaconnecthub.com |
| Address | [TO COMPLETE: registered address] |
| Data Protection Officer | [TO COMPLETE: name, role, or state not appointed] |