Created: 21st February 2023

INTRODUCTION

At darey.io (‘we’, ‘us’ or ‘our’), we recognise the importance of protecting the personal information we collect, and we are committed to ensuring the privacy of your personal information. The purpose of this Privacy Policy is to provide an outline of the way we manage personal information in accordance with privacy laws including but not limited to:

• General Data Protection Regulation (GDPR);
• UK GDPR; and
• the Nigeria Data Protection Regulation (NDPR).

We ensure that our obligation under the privacy laws in different jurisdiction is taken seriously and we will take all reasonable steps to comply with these laws to protect the privacy of all personal information.

By using our Services, you agree to the terms of this Privacy Policy. Please read this Privacy Policy as well as our Terms and Conditions carefully, as they govern your use of our Services. If you do not agree to this Privacy Policy, please do not use our Services.

You can find information about us and how we collect, use, and store your personal information in each section of this Privacy Policy:

• Who we are
• What personal information we collect
• How we use your personal information
• Our legal basis for using your personal information
• Who we share your personal information with and why
• Retention of your personal information
• How we keep your personal information secure
• Transfers of personal information
• Your rights
• How to contact us

WHO ARE WE

Darey.io is an online platform that provides easy, affordable access to self-paced, and instructor led tech learning on a world-class peer-to-peer learning platform.

WHAT PERSONAL INFORMATION WE COLLECT

We collect a variety of information that you provide directly to us. In general, we collect information from you via:

• Registering with Darey.io: When you register on our website, when you create and update your profile, and when you purchase any plan on our website, we and third parties working with us will collect the following information:
  • Name
  • Email address
  • Phone number
  • Date of Birth / Age
  • Country of nationality
  • Credit/debit card information
  • Photos you upload on your profile account
  • Data relating to your use of our website
  • Information provided by you when you correspond with us (including via surveys)
  • Other information you choose to provide about your bio, educational, skills and experience
  • Information provided from third party sources, such as our Partners who may invite you to a certain course.
• Learning journey: When you have enrolled for any of our courses, we and third parties may collect and store the following additional information:
  • comments you voluntarily post
  • any email communications with Darey.io to seek user support or to send queries related to a course
  • any content submitted by you during the course, such as projects
  • responses you voluntarily provide to Darey.io
• Requesting additional information on Darey.io courses: We collect information from visitors to our website or social media who express interest in a particular course and wish to be provided with a response to their questions
• Use of Cookies: When you access our website, we may use cookies to track, collect, and aggregate information about your use of our website, including pages you have visited, the specific URLs that brought you to our website, and links embedded on our website that you have accessed. This information may include IP addresses, and any information collected by cookies. This may also include information such as the time and length of visits to certain pages on our website and page interaction information. Where you do not want information collected using cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/

HOW WE USE YOUR PERSONAL INFORMATION

Your information is an integral part of our business. We use your information, including your personal information, for the following purposes:

• Create and manage your accounts and profiles in order to provide the Services you signed up for;
• Process your payment plan to access your preferred courses on our learning portal;
• Communicate with you about your account by:
  • Responding to your questions and concerns;
  • Sending you administrative messages and information, including messages from instructors and notifications about changes to our Service; and updates to our agreements;
  • Sending you information, such as by email about your progress in courses and related content, rewards programs, new services, new features, promotions, newsletters, and other available content;
• Manage your account and account preferences and personalise your experience;
• Facilitate our Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
• Solicit feedback from users (Account Data; Communications and Support);
• Market products, services, surveys, and promotions;
• Learn more about you by linking your data with additional data through third-party data providers and/or analysing the data with the help of analytics service providers;
• Improve our Services and develop new products, services, and features (all data categories);
• Analyse trends and traffic, track purchases, and track usage data;
• As required or permitted by law;
• As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services; or
• Fulfil any other purpose at your direction.

OUR LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION

Our legal basis for collecting and using your personal information described in this Privacy Policy depends on the personal information we collect and the specific context in which we collect it.

Darey.io may process your personal information because:

• We need to perform a contract with you;
• With your consent i.e., when you have given us permission to do so;
• The processing is in our legitimate interests, and it’s not overridden by your rights; or
• To comply with any procedures, laws and regulations which apply to us.

WHO WE SHARE YOUR PERSONAL INFORMATION WITH AND WHY

We may share your information with the following third parties. Please note that any third parties’ use of your personal information will not be governed by their own Privacy Policy.  We suggest that you carefully review any third-party Privacy Policies that may apply to you.

Third parties that may receive your information include but not limited to:

• our payment services providers like Paystack and Stripe.
• customer relationship management service providers (which allows us, for example, to send personalized email communications to you);
• our file storage and management service providers;
• your employer or third parties who may invite you to enroll for our program for training;
• if we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets, provided that they continue to use your information in accordance with the terms of this Privacy Policy;
• if all, or substantially all of our assets, are acquired by a third party provided that they continue to use your information in accordance with the terms of this Privacy Policy, in which case information held by us will be one of the transferred assets; and
• Any entity to which we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Terms and other legal requirements; or to protect our rights, property, or safety, our users, or others.

RETENTION OF YOUR PERSONAL INFORMATION

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed or as required by law or regulation. The length of time we retain personal information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

HOW WE KEEP YOUR PERSONAL INFORMATION SECURE

The main risk of our processing of your personal information is if it is lost, stolen, or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private.

For this reason, we are committed to protecting personal information from loss, misuse, disclosure, alteration, unauthorized access, unavailability, and destruction. We take all reasonable precautions to safeguard the confidentiality of personal information, including through use of appropriate organizational and technical measures.

• Organizational measures include: physical access controls to our premises, implementing internal policies and staff training and ensuring confidentiality obligations are imposed on our employees and third parties.
• Technical measures include: requiring passwords for access to our systems, and the use of encryption and anti-virus software.

We are committed to ensuring the confidentiality of your personal information that we hold and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.

In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information that you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk.

TRANSFERS OF PERSONAL INFORMATION

Because of the nature of our business and presence in Nigeria and UK, we may transfer your personal information internationally when carrying out the activities described in this Policy. We shall put in all reasonable efforts to make sure the data transfer complies with applicable law and provide you with the same level of protection as it has in your jurisdiction.

YOUR RIGHTS

You have some rights in relation to your personal information we hold about you.  For example, under certain circumstances, you have the right to:

• Request access to your personal information (sometimes known as a ‘Data Subject Access Request’). This enables you to receive a copy of the personal information we hold about you.
• Request correction of the personal information that we hold about you. This enables you to ask us to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of personal information. This enables you to ask us to delete or remove your personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (kindly see below).
• Object to processing of your personal information where we are relying on a lawful basis like consent and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing, research, analytics or publication purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

The rights set out above are not absolute and are subject to a number of important exemptions and limitations that mean we don’t always need to comply with your request.

PRIVACY VIOLATION AND AVAILABLE REMEDIES

In the event of a breach of personal information, we shall within 72 (seventy-two) hours of having knowledge of such breach report the details of the breach to the Authorities. Furthermore, where we ascertain that such a breach is detrimental to your rights and freedom in relation to your personal information, we shall take reasonable steps to inform you of the breach incident.

Where you have concerns relating to the processing of your personal information or require any clarification on this policy, please notify us through or contact details provided below:

Address: Thames Industrial Park, Building 13 Princess Margaret Rd, East Tilbury, Tilbury RM18 8RH, UK.
1207 Delaware Ave #1048, Wilmington DE 19806, USA.

Email: Support@darey.io

Phone Number: +1 (469) 214-4619 / +44 147 394 3208 / +234 (0) 817 147 4604

We will respond to your concerns within one month of receiving your notice.

ALTERATION TO PRIVACY POLICY

We will update this Privacy Policy as the need may arise. Kindly visit this page from time to time to check for any amendments.