Privacy Policy

1. INTRODUCTION

Binal Technologies Limited ("we," "us," or "our") is entrusted with your information, and we recognise that this is a significant responsibility. This Privacy Policy outlines how we collect, process, secure, and share information when you interact with our digital ecosystem. This Policy is formulated in strict compliance with the Nigeria Data Protection Act (NDPA) 2023 and other relevant global data protection frameworks.

2. SCOPE OF THIS POLICY

This Privacy Policy applies to all users, clients, and visitors interacting with our websites and applications, including but not limited to:

• Edu-Slick
• DECAS
• Jobcleek
• Informational Websites (e.g., binaltechnologies.com)
• Custom Software developed for third-party clients.

3. OUR LEGAL ROLES (CONTROLLER VS. PROCESSOR)

To understand how your data is handled, it is critical to distinguish our legal roles under the NDPA 2023:

• As a Data Processor: When institutions (Schools, Employers, Examining Bodies) use our platforms to manage their own records, they are the Data Controllers. We process student records, examination scores, and specific employer-candidate pipelines strictly on their behalf. We do not own this operational data.
• As a Data Controller: We act as the Data Controller when you register directly on our platforms for a core account (e.g., Job applicants registering directly on Jobcleek, or administrators creating billing profiles). We control how this core profile data is secured, stored, and authenticated across our ecosystem.

4. DATA WE COLLECT

We may collect the following data to provide our services:

• General & Contact Information: Name, email addresses, telephone numbers, and institution names.
• Operational & End-User Data: Resumes/CVs, educational details, student academic records, and attendance logs.
• Technical Information: IP address, browser type, operating system, and platform interaction metrics.
• Geolocation Data: (See Section 5).

5. GEOLOCATION & SAT APP TRACKING

By using the Edu-Slick SAT App, you consent to the collection of location data.

• Purpose: We collect GPS data strictly to enable the QR Location fencing feature. This ensures staff and students are physically within the school premises when logging attendance.
• Privacy: The SAT App does not track your location when the app is closed or not in use. You must grant location access via your device settings for the attendance feature to function.

6. USE OF AI FUNCTIONALITY

Edu-Slick includes AI-powered features designed to assist staff in generating lesson notes, plans, and educational questions.

• Processing: The AI processes text inputs to generate relevant educational responses. This data is processed dynamically and is not permanently stored or used to train public AI models.
• Responsibility: We do not feed sensitive student personal data (PII) into the AI. Users are responsible for ensuring that inputs do not violate third-party rights or contain sensitive personal information.

7. LEGAL BASIS FOR PROCESSING

We process your data under the following legal bases:

• Contractual Obligation: To provide the services you or your institution have requested.
• Consent: For sending marketing newsletters, non-essential cookies, or explicit opt-ins.
• Legitimate Interests: To improve our services, deploy AI functionalities, and prevent fraud.
• Legal Obligation: To comply with NDPC regulations, tax laws, or criminal investigations.

8. WHO WE SHARE DATA WITH

We do not sell your personal data. We may share data with:

• Domain Administrators: If you use Edu-Slick through a school/company, your IT administrator can access your account, reset your password, and archive your data.
• Authorised Sub-Processors: Cloud storage providers (e.g., Hostinger, Truehost), payment processors, and analytics platforms.
• Legal Authorities: To comply with lawful government or regulatory requests.

9. DATA HOSTING & CROSS-BORDER TRANSFERS

To guarantee optimal security and uptime, we utilise premium international cloud infrastructure. You acknowledge that your data may be transferred, processed, and stored on secure servers outside Nigeria (e.g., Hostinger servers located in the EU/US). We ensure appropriate safeguards, such as Standard Contractual Clauses (SCCs), are in place to comply with NDPA cross-border data transfer regulations.

10. KEEPING DATA SECURE & BREACH NOTIFICATION

We use robust technical measures including SSL encryption, firewalls, and role-based access controls. In the event of a suspected personal data breach, we adhere to a strict internal protocol. We will notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of a reportable breach, and notify affected Data Controllers without undue delay.

11. COOKIES & ANALYTICS

We use cookies and similar technologies to enhance your experience:

• Essential Cookies: Strictly necessary for platform security and login sessions.
• Analytics (Google Analytics): We use Google Analytics to track website traffic and user behaviour. You can opt-out by installing the Google Analytics opt-out browser add-on.

12. YOUR DATA PROTECTION RIGHTS

Under the NDPA 2023, you have the right to request access to, correction of, erasure of, or restriction of processing for your personal data.

Important Note: If you are a student or parent, you must direct your data rights requests directly to your School (the Data Controller), and we will assist them. If you are a direct Jobcleek applicant, you may submit data rights requests directly to us to delete your core profile, but we cannot delete records already downloaded or processed by independent employers you applied to.

To exercise your direct rights with us, contact: privacy@binaltechnologies.com.

13. EXTERNAL CUSTOM SOFTWARE LIABILITY

For custom software developed for third-party clients: Once the bespoke software is handed over, the client becomes the sole Data Controller. Binal Technologies assumes no liability for the data processed on external, third-party managed applications.

14. CHANGES TO THIS POLICY

Binal Technologies reserves the right to update this Privacy Policy as required by law or operational changes. Updates will be posted on our website, and your continued use constitutes acceptance.