1. Introduction

Welcome to Everest Freedom Academy ("EFA", "we", "us", or "our"). We are committed to protecting your privacy and the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile application, and educational services (collectively, the "Service").

By using our Service, you consent to the data practices described in this Privacy Policy. If you do not agree with any part of this policy, please do not use our Service.

2. Information We Collect

We collect several types of information from and about users of our Service:

2.1 Personal Information You Provide to Us

When you register for an account, enroll in courses, or contact us, we may collect:

• Account Information: Name, email address, phone number, date of birth, and password
• Profile Information: Profile photo, educational background, professional experience, and interests
• Payment Information: Billing address, payment method details (processed securely by our payment partners)
• Communication Data: Messages, feedback, and support requests you send to us
• Verification Data: NIN (National Identification Number), bank account details for rewards payout

2.2 Information Automatically Collected

When you use our Service, we automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent, courses accessed, assessment results, and completion data
• Location Data: Approximate location based on IP address
• Activity Data: Login history, course progress, reward earnings, and transaction history

3. How We Use Your Information

We use the information we collect for the following purposes:

• Provide and Maintain the Service: Create and manage your account, enroll you in courses, track progress, and deliver educational content
• Learn & Earn Program: Calculate and distribute rewards based on your learning activities
• Improve the Service: Analyze usage patterns to enhance course offerings and user experience
• Communication: Send important updates, course notifications, reward alerts, and respond to inquiries
• Security: Detect and prevent fraud, unauthorized access, and other security issues
• Legal Compliance: Comply with applicable laws, regulations, and legal processes
• Marketing: With your consent, send promotional materials about new courses and features

4. Information Sharing

We do not sell your personal information. We may share your information in the following circumstances:

• Service Providers: We share data with trusted third-party vendors who assist with payment processing, hosting, analytics, and customer support
• Partners: With your consent, we may share information with partner organizations for sponsorship and mentorship opportunities
• Legal Requirements: We may disclose information if required by law or to protect our rights, property, or safety
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred

5. Cookies & Tracking

We use cookies and similar tracking technologies to enhance your experience. Cookies are small text files stored on your device that help us remember your preferences and understand how you use our Service.

Types of cookies we use:

• Essential Cookies: Required for core functionality (login, course access, rewards tracking)
• Preference Cookies: Remember your settings and preferences
• Analytics Cookies: Help us understand how users interact with our platform
• Marketing Cookies: Used to deliver relevant advertisements (with your consent)

You can control cookie settings through your browser preferences. However, disabling essential cookies may affect your ability to use the Service.

6. Data Security

We implement industry-standard security measures to protect your personal information:

• Encryption: All data transmitted between your browser and our servers is encrypted using TLS/SSL protocols
• Secure Storage: Passwords are hashed using bcrypt; sensitive data is encrypted at rest
• Access Controls: Strict internal access policies limit who can view user data
• Regular Audits: We conduct regular security assessments and vulnerability scans

While we strive to protect your data, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide our services. Even after account deletion, we may retain certain information for:

• Legal compliance and regulatory requirements (up to 7 years)
• Fraud prevention and security purposes
• Legitimate business interests (anonymized analytics)

Course completion records and reward history may be retained to verify eligibility for future programs.

8. Your Rights

Depending on your location, you may have certain rights regarding your personal information:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal obligations)
• Restriction: Request restriction of processing in certain circumstances
• Portability: Request transfer of your data to another service provider
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for marketing communications at any time

9. Children's Privacy

Our Service is intended for users who are at least 16 years old. We do not knowingly collect personal information from children under 16. If we become aware that we have collected data from a child under 16, we will take steps to delete that information promptly.

Users between 16 and 18 years of age must have parental or guardian consent to use our Service.

10. Third-Party Links

Our Service may contain links to third-party websites, services, and applications. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We take appropriate measures to ensure that your data receives adequate protection in accordance with applicable laws.

Our servers are primarily located in Nigeria and the European Union. By using our Service, you consent to the transfer of your data to these locations.

12. Policy Changes

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the new policy on this page
• Sending an email notification to registered users
• Displaying a notice within the Service

The "Last Updated" date at the top of this page indicates when changes were made. Your continued use of the Service after changes become effective constitutes acceptance of the updated policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: privacy@efa.edu.ng
• Data Protection Officer: dpo@efa.edu.ng
• Phone: +234 123 456 7890
• Address: 123 Education Avenue, Abuja, Nigeria

For complaints, you may also contact the Nigeria Data Protection Commission (NDPC) at info@ndpc.gov.ng.