Ascent Learn — Privacy Policy

Effective / last updated: September 2026 · Version: 1.2

Data Controller: Ascent Tech Hub Africa Nig. Ltd. (trading as Ascent Learn) ("Ascent Learn", "we", "us", "our"), RC 7983215, of Plot 12, Oladele Kadiri Close, off Nob-Oluwa Street, Ogba-Ikeja, Lagos, Nigeria. Contact / Data Protection Officer (DPO): Durodola Abdulhad · privacy@ascentlearn.academy · +234 811 870 9100.

1. Who this covers & our commitment

This policy explains how we collect, use, store, share, and protect the personal data of everyone who interacts with Ascent Learn — website visitors, prospective students, enrolled students, parents/guardians, instructors, and partners — whether you engage with us online or at our physical hub in Ogba/Ikeja, Lagos.

Our audience spans Nigeria, other African countries, and the diaspora/overseas. We are committed to handling your data lawfully, fairly, transparently, and securely, in line with the laws in Section 9.

2. The personal data we collect

• Identity & contact: name, email, phone/WhatsApp number, address, date of birth, gender (optional), photo/ID (where required for verification or certificates).
• Enrolment & academic: course(s) chosen, mode (online/physical), attendance, assignments, projects, grades, certificates, feedback.
• Payment: transaction records, amounts, method, and receipts. We do NOT store full card details — payments are processed by our payment providers (e.g. Paystack/Flutterwave), who handle card data under their own security standards (PCI-DSS).
• Technical & usage: IP address, device/browser, pages visited, and cookies (Section 10) when you use our website or LMS.
• Communications: messages, support tickets, and (where you are notified) call/session recordings for online classes.
• Marketing: your preferences and consent status.
• Feedback & media: course feedback and surveys, and — as a required part of the programme (see Terms §6A) — testimonials, photos, and video/audio recordings of you (e.g. testimonial videos, event photos, class recordings).
• Sensitive data: we do not seek special-category data; if any is provided (e.g. a disability accommodation request), we process it only with your explicit consent and for that purpose.

3. How we collect it

Directly from you (registration, forms, WhatsApp, in-person sign-up, payments); automatically (website/LMS cookies and logs); and occasionally from partners you've engaged (e.g. a sponsor or employer paying for your seat).

4. Why we use it & our legal bases

5. Marketing & your choices

We send marketing only with your consent (or to existing students about closely related courses, where permitted). Every marketing message includes an opt-out, and you can withdraw consent anytime via privacy@ascentlearn.academy or WhatsApp STOP.

Image/testimonial opt-out (EU/UK & where required): while feedback and testimonials are part of the programme (Terms §6A), if you are in the EU/UK — or anywhere your law requires freely-given consent — you may opt out of public/marketing publication of your image, voice, or video at any time by emailing privacy@ascentlearn.academy. We will not publish it and will remove it from future marketing on request.

6. Who we share your data with

We share data only as needed, with:

• Service providers (data processors) under contract: payment processors (Paystack/Flutterwave), our LMS host, video-class provider (e.g. Zoom), email/WhatsApp tools, cloud storage, and analytics.
• AI tools used in teaching (e.g. ChatGPT/Claude): you should not enter sensitive personal data into third-party AI tools; where a course uses them, we tell you and you use them under those providers' terms.
• Sponsors/employers who fund your seat — limited to enrolment, attendance, and completion (with your awareness at enrolment).
• Authorities/regulators where required by law. We do not sell your personal data.

7. International data transfers

Some providers store or process data outside your country (including outside Nigeria/your African country). Where we transfer personal data across borders, we ensure a lawful basis and appropriate safeguards — e.g. transfer to a jurisdiction with adequate protection, or contractual safeguards (such as Standard Contractual Clauses / equivalent) — as required by the NDPA 2023, GDPR, and other applicable laws. You may request details of the safeguards used.

8. How long we keep it

We keep personal data only as long as necessary: for the duration of your relationship with us, plus retention periods required for tax, legal, accreditation, and legitimate business needs (typically up to [6–7] years for financial records; academic records/certificates may be kept longer to verify credentials). After that, we securely delete or anonymise it.

9. The laws we comply with (multi-jurisdiction)

We design our practices to meet, at minimum:

• Nigeria (primary): the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR) 2019, overseen by the Nigeria Data Protection Commission (NDPC); and the Federal Competition and Consumer Protection Act (FCCPA) 2018.
• Other African countries where our students reside — including Kenya (Data Protection Act 2019), Ghana (Data Protection Act 2012, Act 843), South Africa (POPIA 2013), and others — and the African Union Malabo Convention on data protection.
• Overseas / diaspora: the EU GDPR and UK GDPR / Data Protection Act 2018 where we handle the data of individuals in the EU/UK. Where laws differ, we apply the standard that best protects you.

10. Cookies & website tracking

Our website and LMS use cookies for essential functionality, preferences, and analytics. On your first visit you can accept or decline non-essential cookies via our cookie banner; you can also manage cookies in your browser. See our [Cookie Notice] for details.

11. Children & minors

Our courses are intended for adults (18+). Where a learner is a minor, we require verifiable parent/guardian consent before collecting or processing their data, and we limit processing to what's necessary to deliver the course. Youth-outreach programmes have their own consent process.

12. How we protect your data

We use appropriate technical and organisational measures — access controls, encryption in transit, secure hosting, staff confidentiality, and least-privilege access. No system is perfectly secure, but we work to protect your data and to notify you and the relevant regulator of any breach as required by law (e.g. within the NDPA/GDPR timelines).

13. Your rights

Subject to applicable law, you have the right to: access your data; request correction or deletion; object to or restrict processing; withdraw consent; request data portability; and not be subject to solely automated decisions with legal effect. To exercise any right, contact privacy@ascentlearn.academy — we respond within the timeframe required by law (generally 30 days), and free of charge in most cases.

14. Complaints

If you're unhappy with how we handle your data, please contact our DPO first. You also have the right to complain to your data-protection regulator — in Nigeria, the NDPC ([ndpc.gov.ng]); in other countries, your national data-protection authority (e.g. the ODPC Kenya, the Information Regulator South Africa, the ICO in the UK, or your EU supervisory authority).

15. Changes to this policy

We may update this policy; the "Last updated" date shows when. Material changes will be notified to enrolled students (e.g. by email/WhatsApp or LMS notice).

16. Contact

Ascent Learn — Data Protection Plot 12, Oladele Kadiri Close, off Nob-Oluwa Street, Ogba-Ikeja, Lagos · privacy@ascentlearn.academy · +234 811 870 9100 · https://ascentlearn.academy