Privacy Policy

Effective Date: 1st March, 2026

This Privacy Policy explains how Edukate (“Edukate”, “we”, “us” or “our”) collects, uses, stores, shares and otherwise processes personal data when you visit or use edukate.nimgine.online and any related services, features, content, applications or communications we provide (together, the “Platform”).

Edukate is an online eLearning marketplace and course platform where prospective students can discover and enrol in courses, and instructors can create accounts, upload course materials, and share knowledge and skills with users in different countries. This Privacy Policy applies to visitors, prospective students, registered students, instructors, and other users of the Platform.

Please read this Privacy Policy carefully. By accessing or using the Platform, you acknowledge that your personal data may be processed as described in this Policy, subject to applicable law.

1. Who We Are

The data controller responsible for personal data collected through the Platform is:

Company Name: Nimgine™ Limited
Website: edukate.nimgine.online
Email: contact@nimgine.online
Contact Number: +234 705 521 6975

If you have any questions about this Privacy Policy or how your personal data is handled, you can contact us using the details above.

2. Scope of This Policy

This Privacy Policy covers personal data we collect when you:

• visit or browse the Platform;

• create an account;

• enrol in, purchase, access or interact with courses;

• apply to become, or act as, an instructor;

• upload course content or profile information;

• communicate with us or with other users through the Platform;

• subscribe to newsletters or service notifications;

• contact customer support; or

• otherwise use features, tools or integrations made available through the Platform.

This Policy does not apply to third-party websites, applications or services that may be linked to, integrated with, or embedded in the Platform. Those third parties may have their own privacy notices and terms.

3. Information We Collect

We may collect personal data directly from you, automatically from your use of the Platform, and from third parties where applicable.

3.1 Information You Provide Directly

Depending on how you use the Platform, we may collect:

A. Account and Registration Information

• full name;

• username or display name;

• email address;

• password and account credentials;

• country or region;

• profile photograph or avatar;

• account preferences and settings.

B. Student Information

If you use the Platform as a student or prospective student, we may collect:

• enrolment and checkout details;

• course interests and preferences;

• learning goals;

• saved courses, wishlists or bookmarks;

• course progress, completion status, quiz or assessment activity;

• certificates or achievements generated through the Platform, where applicable;

• feedback, reviews, ratings, comments, forum posts or other content you submit.

C. Instructor Information

If you apply to become or act as an instructor, we may collect:

• instructor biography, profile information and professional background;

• areas of expertise, qualifications or experience you choose to provide;

• course titles, descriptions, pricing information and category selections;

• uploaded course materials, such as videos, documents, images, audio, assignments, quizzes and downloadable resources;

• communications relating to course submissions, approvals, moderation or support;

• payout or payment-related details where instructor payments are supported, which may be handled in whole or in part by third-party payment providers.

D. Communications and Support Information

We may collect:

• messages you send to us;

• support enquiries, complaints or feedback;

• communications between users where messaging, discussion, review, comment or forum functions are offered on the Platform;

• survey responses or other information you choose to provide.

E. Marketing and Subscription Information

If you opt in or where otherwise permitted by law, we may collect:

• newsletter sign-up details;

• communication preferences;

• responses to promotional campaigns or user research.

3.2 Information Collected Automatically

When you visit or use the Platform, we may automatically collect certain information, including:

• IP address;

• browser type and version;

• device type, operating system and device identifiers;

• language preferences;

• pages viewed and features used;

• dates, times and duration of visits;

• referral URLs and navigation paths;

• log data, crash data and diagnostic information;

• approximate location derived from IP address;

• analytics and usage information about how users interact with the Platform, courses and content.

3.3 Cookies and Similar Technologies

We may use cookies, pixels, tags, local storage and similar tracking technologies to:

• keep you signed in;

• remember preferences and settings;

• understand how the Platform is used;

• improve performance and usability;

• support security, fraud prevention and abuse detection;

• measure the effectiveness of communications or campaigns, where applicable.

Some cookies may be necessary for the Platform to operate, while others may be used for analytics, functionality or advertising-related purposes, depending on how the Platform is configured.

You can usually control cookies through your browser settings. Where required by applicable law, we may also provide a cookie banner or consent management tool that allows you to accept or reject certain categories of cookies.

3.4 Information from Third Parties

We may receive personal data from third parties, such as:

• payment processors, in connection with purchases, refunds, chargebacks or payouts;

• analytics providers;

• hosting, communications or support service providers;

• authentication or login providers, if social or single sign-on features are offered;

• embedded media, integration or external tool providers;

• other users, for example where an instructor or student refers to you or interacts with you through the Platform.

4. How We Use Personal Data

We may use personal data for the following purposes:

• to create, maintain and manage user accounts;

• to provide the Platform and its features;

• to allow students to discover, purchase, enrol in and access courses;

• to allow instructors to create profiles, upload and manage course content, and engage with learners;

• to process transactions, payments, refunds and related records;

• to communicate with you about your account, courses, purchases, support requests or Platform updates;

• to personalise user experience, recommendations and relevant content;

• to monitor course participation, completion and engagement;

• to moderate content and user activity;

• to detect, investigate and help prevent fraud, unauthorised access, abuse, spam, infringement, misuse and other harmful or unlawful activity;

• to maintain the safety, integrity and security of the Platform;

• to troubleshoot technical issues and improve functionality, performance and design;

• to carry out analytics, research, auditing and internal reporting;

• to comply with legal obligations and enforce our policies, terms and rights;

• to send service messages and, where permitted, marketing communications.

5. Lawful Bases for Processing

Where applicable under laws such as the UK General Data Protection Regulation or the EU General Data Protection Regulation, we may rely on one or more of the following lawful bases for processing personal data:

• Performance of a contract: where processing is necessary to provide the Platform, create and manage accounts, process enrolments, deliver courses, handle instructor content, and administer transactions.

• Legitimate interests: where processing is necessary for our legitimate interests, such as operating and improving the Platform, securing services, preventing fraud, moderating content, understanding user engagement, and communicating about relevant service matters, provided those interests are not overridden by your rights and interests.

• Consent: where you have given consent, such as for certain cookies, optional marketing communications, or other processing activities that require consent under applicable law.

• Legal obligation: where processing is necessary to comply with applicable laws, regulations, court orders or lawful requests from public authorities.

• Vital interests or public interest: where applicable and permitted by law, in limited circumstances.

The lawful basis may vary depending on the specific activity and your location.

6. Payments and Financial Information

If you purchase a course, pay platform fees, or receive payouts as an instructor where such functionality is available, payment processing may be handled by third-party payment service providers.

Edukate may receive limited transaction-related information, such as:

• payment confirmation;

• transaction amount;

• billing status;

• partial payment method details;

• refund or chargeback information.

We do not state that we store full payment card details unless that is in fact how the Platform operates. In many cases, payment card information is collected and processed directly by third-party payment providers under their own privacy notices and security standards. Their handling of your information is subject to their own terms and privacy policies.

7. Public, Shared and Course-Related Content

Because Edukate is a learning marketplace, some information may be visible to other users depending on how the Platform is designed and how you use it.

7.1 Instructor Profiles and Course Content

Instructor names, biographies, profile images, course descriptions, course categories, reviews, ratings, and certain course-related information may be visible publicly or to registered users.

Course materials uploaded by instructors may be made available to enrolled students and, in some cases, preview content may be visible to the public or prospective students.

7.2 Student Interactions

If the Platform allows reviews, ratings, comments, questions, forum discussions, community posts or messages, information you submit through those features may be visible to instructors, other students or other users, depending on the feature.

7.3 Responsibility for Submitted Content

Users should avoid posting or uploading personal data they do not wish to share. Instructors are responsible for ensuring that course materials and uploads comply with applicable law and do not unlawfully disclose the personal data of others.

8. How We Share Personal Data

We may share personal data in the following circumstances:

8.1 With Service Providers

We may share personal data with third-party service providers that help us operate the Platform, including providers of:

• hosting and infrastructure;

• analytics and performance monitoring;

• payment processing;

• email delivery and notifications;

• customer support;

• security and fraud prevention;

• file storage, content delivery, embedded media or external tools.

These providers may process personal data on our behalf and under appropriate contractual or legal safeguards where required.

8.2 Between Students and Instructors

We may share information between students and instructors as necessary to deliver courses and support learning activity, such as:

• enrolment status;

• course participation information;

• submitted assignments, questions, comments or reviews;

• profile information that users choose to make available.

8.3 With Affiliates or Successors

If Edukate is involved in a merger, acquisition, financing, restructuring, sale of assets or similar business transaction, personal data may be disclosed to relevant parties, subject to appropriate confidentiality and legal safeguards.

8.4 For Legal, Safety and Compliance Reasons

We may disclose personal data where reasonably necessary to:

• comply with applicable law, regulation, legal process or lawful request;

• enforce our policies, terms and contractual rights;

• detect, investigate or prevent fraud, security incidents, abuse or illegal activity;

• protect the rights, property, safety or security of Edukate, our users or others.

8.5 With Your Consent or Direction

We may share personal data where you ask us to do so, clearly consent, or choose to use a feature that requires such sharing.

9. International Data Transfers

Because Edukate may serve users in multiple countries and may rely on service providers located in different jurisdictions, personal data may be transferred to, stored in, or accessed from countries outside your own.

Where applicable law requires safeguards for international transfers, we may use appropriate transfer mechanisms, such as contractual safeguards, adequacy decisions, or other lawful measures. The availability and suitability of those mechanisms may depend on the countries involved and the way the Platform is structured.

Users accessing the Platform from outside the country where Edukate or its service providers operate should be aware that their personal data may be processed internationally.

10. Data Retention

We keep personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• provide the Platform and maintain accounts;

• keep course records, enrolment history and learning-related information;

• manage instructor content and platform operations;

• comply with legal, accounting, tax, reporting and compliance obligations;

• resolve disputes and enforce agreements;

• maintain security, prevent fraud and keep appropriate business records.

Retention periods may vary depending on the type of data, the purpose of processing, system design, contractual requirements and legal obligations. Specific retention periods should be documented internally and inserted where appropriate.

Indicative placeholder: Personal data may be retained for [Insert retention period or retention criteria] after account closure or for longer where required by law or legitimate business needs.

11. Data Security

We take reasonable technical, organisational and administrative measures designed to protect personal data against unauthorised access, loss, misuse, alteration, disclosure or destruction.

These measures may include access controls, authentication protections, monitoring, encryption in transit where supported, secure hosting practices, and internal processes designed to limit unnecessary access to personal data.

However, no online platform or method of transmission or storage is completely secure. For that reason, we cannot guarantee absolute security.

Users are responsible for keeping their passwords confidential and for notifying us promptly if they believe their account has been compromised.

12. Your Rights

Subject to applicable law and depending on your location, you may have the right to:

• request access to personal data we hold about you;

• request correction of inaccurate or incomplete personal data;

• request deletion of your personal data;

• request restriction of processing;

• object to certain processing, including processing based on legitimate interests;

• withdraw consent where processing is based on consent;

• request portability of certain personal data in a structured, commonly used and machine-readable format;

• opt out of certain marketing communications;

• lodge a complaint with a relevant data protection or supervisory authority.

These rights are not absolute and may be subject to legal exceptions, verification steps and limitations permitted by applicable law.

To exercise your rights, please contact us at [Insert privacy contact email] or [Insert support email]. We may need to verify your identity before responding to a request.

13. Account Settings and Communication Preferences

You may be able to access, update or delete certain account information through your account settings on the Platform.

You may also be able to manage:

• profile visibility;

• communication preferences;

• newsletter subscriptions;

• notification settings;

• certain course, instructor or student interaction preferences.

Even if you opt out of marketing messages, we may still send important service-related communications, such as notices about your account, transactions, policy updates, security matters or course access.

14. Moderation, Fraud Prevention and Platform Safety

To help maintain a safe and trustworthy learning environment, we may monitor, review or moderate content, interactions, uploads, reports and platform activity.

This may include processing personal data to:

• review instructor submissions and course materials;

• investigate reported content or conduct;

• detect fake accounts, spam, fraud or suspicious transactions;

• prevent misuse of platform tools or infringement of rights;

• enforce community standards, content rules and platform terms.

Moderation may involve a combination of manual review, automated tools, or both, where appropriate and permitted by law.

15. Children’s Privacy and Minimum Age

Edukate is intended for users who meet the minimum age required to enter into binding agreements and use online services under applicable law in their jurisdiction.

The Platform is not intended for children under [Insert minimum age, e.g. 13, 16 or other applicable age] without appropriate parental or guardian involvement where required by law. If Edukate targets or allows younger learners in any jurisdiction, additional disclosures, consent flows and safeguarding measures may be required.

We do not knowingly collect personal data from children in violation of applicable law. If you believe a child has provided personal data unlawfully through the Platform, please contact us so we can review and take appropriate action.

16. Third-Party Links, Embedded Content and Integrations

The Platform may contain links to third-party websites, plug-ins, software tools, payment pages, embedded videos, social media features or learning-related integrations.

When you interact with those third parties, your personal data may be collected or processed by them under their own terms and privacy practices. Edukate is not responsible for the privacy, security or content practices of third-party services that we do not control.

Users should review the privacy notices of those third parties before providing personal data or using their services.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the Platform, legal requirements, operational practices or data processing activities.

When we make material changes, we may provide notice by updating the effective date above, posting the revised policy on the Platform, or using other appropriate communication methods where required by law.

Your continued use of the Platform after an updated Privacy Policy becomes effective may be treated as acknowledgement of the revised Policy, to the extent permitted by applicable law.

18. Contact Us

If you have questions, concerns or requests relating to this Privacy Policy or your personal data, please contact:

Edukate
Website: edukate.nimgine.online
Email: [Insert support email]
Privacy contact: [Insert privacy contact email, if different]
Postal address: [Insert registered business address]

If applicable law gives you the right to complain to a data protection authority, you may also contact the relevant authority in your country or region.

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Assumptions / Information Needed

Before publication, please customise and confirm the following:

• [Insert effective date]

• [Insert legal entity name or business owner name]

• [Insert support email]

• [Insert privacy contact email, if different]

• [Insert registered business address]

• [Insert retention period or retention criteria]

• [Insert minimum age, e.g. 13, 16 or other applicable age]

• Confirm whether Edukate acts only as a platform provider or also directly sells courses in its own name in some cases

• Confirm which cookies and tracking tools are actually used

• Confirm which third-party providers are used for hosting, analytics, payments, email delivery, support, storage and embedded content

• Confirm whether instructor payouts are supported and how payout information is handled

• Confirm which user profile fields, course pages, reviews, comments or other content are public or visible to enrolled users only

• Confirm actual international transfer mechanisms, where applicable

• Confirm the process for data subject rights requests and the appropriate response contact

• Confirm whether children or minors are permitted to use the Platform in any jurisdiction, and under what safeguards

• Confirm whether any additional jurisdiction-specific disclosures are needed for the countries in which Edukate actively operates

Legal Review Notice: This draft is for general informational and drafting purposes only and should be reviewed and adapted by a qualified legal professional.