PRIVACY POLICY

CRAMEASY LTD

CramEasy (“we”, “our”, or “us”) is committed to protecting your privacy and personal data in line with the Nigerian Data Protection Act 2023, the Cybercrimes (Prohibition, Prevention, Etc.) Act 2015, and other applicable laws of the Federal Republic of Nigeria. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our services. It also explains your rights and how you can exercise them.

CramEasy is strictly an educational service designed to help students study better and easier, take tests from uplodaded materials, and engage with learning materials. Where our users are under 18, we rely on the Nigeria Data Protection Act’s educational necessity basis to process children’s personal data in a way that is necessary for the provision of educational services, in the best interest of the child, and limited to what is required for learning purposes. We do not use children’s data for advertising, entertainment, or any unrelated purposes.

This privacy policy applies to all CramEasy users who use our platform to upload documents, take tests, or interact with our services.

Lawful Basis for Processing: We will only process your personal data when we have your consent.

You also can view this information at any time, either in settings related to those features and/or online at https://crameasy.com/privacy-policy

1. Personal Information We Collect

Depending on how you use CramEasy, we may collect:

  • Account Information: When you create an account with us, we will collect information associated with your account, including your name, contact information, account credentials, date of birth, payment information, and transaction history, (collectively, “Account Information”).
  • User data: We collect Personal Data that you provide in the input to our Services (“Content”), including content you upload, such as documents you upload for assessment purposes, images, and audio, your Internet Protocol (IP) address, browser type and configuration, the date and time of your request, and information on how you engage with our Services depending on the features you use.
  • Other Information You Provide: We collect other information that you may provide to us, such as when you participate in our events or surveys (collectively, “Other Information You Provide”).
  • Device Details: We collect information about the device you use to connect to our Services. This can include the device name, operating system, unique device identifiers, and the browser in use. The specific data collected may vary depending on your device type and settings.
  • Location Data: We may determine your general location based on your device’s IP address for purposes such as enhancing security, detecting unusual login activity, and improving your overall experience. Some Services may also allow you to share more precise location data from your device, such as GPS-based information, if you choose to enable it.
  • Cookies and Related Technologies: We use cookies and similar tools to operate, manage, and enhance our Services.

NOTE: You are not required to provide all personal information requested, but failure to do so may limit your access to our services.

2. Special Note for User & Content Uploads

You must not upload any personal or sensitive personal data belonging to another individual without their explicit, documented consent.

You may only upload content that you created yourself or that you have lawful permission to use. You are solely responsible for ensuring that your uploads do not infringe on the rights of others.

You must not upload, share, or otherwise submit any material that:

  • Contains threats, harassment, hate speech, or promotes discrimination;
  • Contains obscene, pornographic, or indecent content;
  • Promotes violence, illegal activity, or self-harm;
  • Violates any applicable Nigerian laws or regulations;
  • Contains malicious code, viruses, or files intended to damage or interfere with our systems or other users’ devices.

NOTE: You are solely responsible for the material you upload and for ensuring that such material complies with all applicable laws, including the Nigeria Data Protection Act 2023. We are not responsible for the accuracy, legality, or appropriateness of any content submitted by users, nor for any consequences arising from reliance on the Services.

3. How We Use Your Personal Information

We may use Personal Data for the following purposes:

  • To provide, analyze, and maintain our Services;
  • To improve and develop our Services and conduct research, for example to develop new product features;
  • To communicate with you, including to send you information about our Services and events, for example about changes or improvements to the Services;
  • To prevent fraud, illegal activity, or misuses of our Services, and to protect the security of our systems and Services;
  • To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, CramEasy, or third parties.

As noted above, we may use Content you provide us to improve our Services, for example to identify the most useful features on our software application.

NOTE: We do not sell your personal information to third parties.

4. Children’s Privacy

In accordance with the Nigeria Data Protection Act 2023, a child is defined as any individual under the age of 18 years. As our Services are designed solely for educational purposes, we require verifiable parental or guardian consent before collecting, using, or processing a child’s personal data. We will use such data only to provide and improve our educational services. If we discover that we have inadvertently collected a child’s personal data without the required consent, we will take immediate steps to delete such information and, where necessary, notify the parent or guardian.

5. Data Retention

We will keep your personal data only for as long as necessary to deliver our services to you, or for other lawful purposes such as resolving disputes, ensuring safety and security, or meeting our legal obligations; for example, Cybercrimes Act two-year traffic data retention rule). When no longer needed, data will be securely deleted or anonymised.

6. Data Security

We implement administrative, technical, and physical safeguards to protect your data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, including encryption of sensitive information, secure authentication for accounts, and engaging in regular security audits. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you provide to the Services. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.

7. Your Rights

Under the Nigeria Data Protection Act, you have the right to:

  • Access your personal data.
  • Correct inaccurate data.
  • Withdraw consent at any time.
  • Request deletion (“right to be forgotten”).
  • Restrict or object to processing.
  • Request data portability.
  • Lodge a complaint with the Nigeria Data Protection Commission (NDPC).

8. Sharing Your Information

We may share your personal data with:

  • Service providers: for hosting, payment processing, analytics (bound by confidentiality and NDPA compliance).
  • Law enforcement agencies: when required by Nigerian law.
  • Partners: only with your consent.

9. Cross-Border Data Transfer

We may store and process your personal data in countries outside Nigeria, for example, where we use cloud service providers whose servers are located abroad. Whenever we transfer your data outside Nigeria, we ensure that the receiving country has adequate data protection laws as determined by the Nigeria Data Protection Commission, or that appropriate safeguards (such as standard contractual clauses) are in place to protect your information. By using our Services, you consent to such transfers, provided they comply with applicable law.

10. Cookies

CramEasy’s website, online services, and interactive applications, do not use any third-party “cookies” or other technologies such as web beacons. Our sites may, to optimize user experiences, use the following cookies:

  • Communications Cookies: These cookies are used to enable network traffic to and from CramEasy’s systems, including by helping us detect any errors.
  • Strictly Necessary Cookies: These cookies are set as required to provide a specific feature or service that you have accessed or requested. For example, they allow us to display our websites in the proper format and language, to authenticate and verify your transactions.
  • Other Cookies: These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness of our services. If you prefer that CramEasy not use cookies, we provide you with the means to disable their use. If you want to disable cookies, simply choose “Block all cookies” in your browser’s privacy settings. Certain features of the CramEasy website may not be available if all cookies are disabled.

11. Changes to This Policy

If we make material changes, we will post a notice on our website at least 7 days before changes take effect, as well as notify you directly if we have your contact information.

CramEasy Contact Information:

info@crameasy.com