Introduction

Achebe Campus ("we," "us," or "our") is committed to protecting your privacy and handling your personal data with transparency, care, and respect. This Privacy Policy explains what information we collect, why we collect it, how we use and share it, and what rights you have in relation to it.

This policy applies to all users of the Achebe Campus platform, including our website, applications, creator tools, community features, and all associated services (collectively, the "Service").

By accessing or using the Service, you confirm that you have read and understood this Privacy Policy. Where we rely on your consent as a legal basis for processing, you have the right to withdraw that consent at any time.

If you have any questions, our contact details are at the end of this document.

1. Who We Are

Achebe Campus is the data controller responsible for your personal information collected through the Service. We are registered and operating as a UK-based entity.

For the purposes of UK GDPR and EU GDPR (where applicable), the data controller is:

Achebe Campus Email: support@achebecampus.com

Where we have appointed a Data Protection Officer (DPO), their contact details are provided in Section 14.

2. Information We Collect

We collect personal information in three main ways: information you provide directly, information collected automatically when you use the Service, and information received from third parties.

2.1 Information You Provide Directly

Account Information When you register for an account, we collect your name, email address, password (stored in encrypted form), and optionally a profile picture.

Profile Information Information you choose to add to your public or private profile, including a bio, location, website links, social media handles, professional background, and any other details you voluntarily provide.

Creator Information If you register as a creator, we collect additional information including your community name and description, payout details (bank account or payment provider information), tax identification information where required, and business or trading name if applicable.

Payment Information When you make or receive payments through the Service, billing details and payment card information are collected and processed by our third-party payment partners. Achebe Campus does not store full payment card numbers on our servers. We retain transaction records including amounts, dates, and payment references.

User Content All content you create, upload, post, or transmit through the Service, including course materials, community posts, comments, direct messages, videos, images, documents, and event recordings.

Communications Information you provide when contacting our support team, submitting feedback, completing surveys, or otherwise communicating with us directly.

Identity Verification Where required for payment processing, legal compliance, or fraud prevention, we may collect government-issued identification documents or other verification materials.

2.2 Information Collected Automatically

Device and Technical Information When you access the Service, we automatically collect information about your device, including browser type and version, operating system, device type and identifiers, screen resolution, language settings, and IP address.

Usage Data We collect information about how you interact with the Service, including pages and features accessed, content viewed, communities joined, time and duration of visits, clicks and navigation patterns, search queries made within the platform, and features used.

Transaction Data Records of purchases, subscriptions, enrolments, and other transactions you complete on the platform, including timestamps and transaction identifiers.

Cookies and Similar Technologies We use cookies, pixel tags, web beacons, local storage, and similar tracking technologies to recognise you, remember your preferences, understand how you use the Service, and serve relevant content. Please see Section 10 for more detail on cookies and how to manage them.

Log Data Our servers automatically record certain information when you use the Service, including access times, pages requested, error messages, referral URLs, and other diagnostic data.

2.3 Information from Third Parties

Social Login Providers If you register or sign in using a third-party authentication provider (such as Google or Apple), we receive certain profile information from that provider, including your name, email address, and profile picture, in accordance with the permissions you have granted to that provider. We do not receive your password from these providers.

Payment Processors Our payment partners share transaction confirmation data, fraud prevention signals, and related information with us to facilitate and secure payments on the platform.

Analytics and Advertising Partners We may receive aggregated or pseudonymised data from analytics providers to help us understand platform usage and performance.

Publicly Available Sources We may supplement our records with information that is publicly available, such as publicly accessible social media profiles, where relevant and lawful.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

3.1 Providing and Operating the Service

Creating and managing your account
Enabling you to access communities, courses, and platform features
Processing payments and managing subscriptions
Facilitating communication between creators and members
Delivering content you have purchased or enrolled in

3.2 Improving and Personalising the Service

Analysing how users interact with the platform to improve features and design
Personalising your feed, recommendations, and experience based on your interests and activity
Conducting research, testing, and product development

3.3 Communications

Sending transactional emails such as purchase confirmations, receipts, and account notices
Notifying you of updates to the Service, Terms of Service, or this Privacy Policy
Responding to your support requests, queries, and feedback
Sending marketing and promotional communications where you have opted in or where we have a legitimate interest in doing so (see Section 3.6)

3.4 Safety, Security, and Fraud Prevention

Detecting, investigating, and preventing fraudulent transactions, abuse, and other illegal or unauthorised activity
Verifying your identity and account information
Monitoring for security vulnerabilities and enforcing our Terms of Service
Protecting the rights, property, and safety of Achebe Campus, our users, and the public

3.5 Legal Compliance

Complying with applicable laws, regulations, and legal obligations
Responding to lawful requests from regulatory authorities, courts, or law enforcement
Maintaining records required by tax authorities and financial regulators

3.6 Legitimate Interests

Where we rely on legitimate interests as our legal basis, we may use your information to:

Prevent and investigate fraud and misuse of the platform
Improve our products and services
Conduct business analytics and reporting
Communicate relevant product updates or service changes

We will only process data under legitimate interests where we have assessed that our interests are not overridden by your rights and freedoms.

3.7 Legal Basis for Processing (UK GDPR / EU GDPR)

Purpose	Legal Basis
Providing the Service and managing your account	Performance of a contract
Processing payments	Performance of a contract
Sending transactional communications	Performance of a contract
Security and fraud prevention	Legitimate interests / Legal obligation
Improving the Service	Legitimate interests
Marketing communications	Consent (opt-in) or Legitimate interests (existing users)
Complying with legal obligations	Legal obligation
Identity verification	Legal obligation / Legitimate interests

4. How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following limited circumstances:

4.1 With Creators

When you join a community or purchase a creator's product, the creator will be able to see your public profile information, your membership status, your enrolment in their courses, and engagement data (such as activity and progress within their community). Creators agree to our Terms of Service and are prohibited from using member data for purposes outside of managing their Achebe Campus community.

4.2 With Other Members

Your public profile information and content posted in public or community spaces will be visible to other members of those communities. Please be mindful of what you share in community settings.

4.3 With Service Providers

We share personal data with trusted third-party vendors and service providers who perform functions on our behalf, including:

Cloud hosting and infrastructure providers
Payment processors and fraud detection services
Email delivery and communication platforms
Customer support tools
Analytics and performance monitoring services
Identity verification providers

All service providers are contractually obligated to use your data only as directed by us, to maintain appropriate security, and to comply with applicable data protection laws.

4.4 For Legal Reasons

We may disclose personal information if we believe in good faith that such disclosure is necessary to:

Comply with a legal obligation, court order, or lawful government request
Enforce our Terms of Service or other agreements
Protect the rights, property, or safety of Achebe Campus, our users, or others
Detect, prevent, or address fraud, security, or technical issues

Where legally permitted, we will attempt to notify you before disclosing your information in response to a legal request.

4.5 Business Transfers

If Achebe Campus is involved in a merger, acquisition, restructuring, or sale of all or a portion of its assets, your personal information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on the Service before your data is transferred and becomes subject to a different privacy policy.

4.6 With Your Consent

We may share your information with third parties when you have given us your explicit consent to do so.

5. International Data Transfers

Achebe Campus operates as a global platform. Your personal information may be transferred to, stored in, and processed in countries other than the one in which you reside, including countries that may not provide the same level of data protection as your home country.

Where we transfer personal data from the UK or European Economic Area to third countries, we ensure appropriate safeguards are in place, including:

Standard Contractual Clauses (SCCs) approved by the European Commission or the UK Information Commissioner's Office
Data Processing Agreements with all service providers that process personal data on our behalf
Adequacy decisions where the receiving country has been determined to provide an adequate level of protection

You may request details of the specific safeguards in place for any international transfer by contacting us at support@achebecampus.com.

6. Data Security

We take the security of your personal data seriously and implement a range of technical and organisational measures to protect it, including:

Encryption of data in transit using TLS/SSL protocols
Encryption of sensitive data at rest
Strict access controls and role-based permissions for our team
Multi-factor authentication requirements for internal systems
Regular security assessments, vulnerability scanning, and penetration testing
Monitoring and logging of access to sensitive systems
Incident response procedures for data breaches
Regular employee training on data protection and security practices

Despite these measures, no method of data transmission or storage over the internet is completely secure. We cannot guarantee absolute security, but we are committed to responding promptly and responsibly to any security incident. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by applicable law.

If you believe your account has been compromised, please contact us immediately at support@achebecampus.com.

7. Your Rights and Choices

Depending on where you are located, you may have certain rights regarding your personal information. We honour these rights for all users to the extent required by applicable law.

7.1 Your Rights

Right of Access You have the right to request a copy of the personal data we hold about you and information about how we process it.

Right to Rectification You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.

Right to Erasure ("Right to be Forgotten") You have the right to request deletion of your personal data in certain circumstances, for example where the data is no longer necessary for the purpose it was collected, or where you withdraw consent and there is no other legal basis for processing.

Right to Restriction of Processing You have the right to request that we restrict the processing of your personal data in certain circumstances, for example while we verify the accuracy of data you have disputed.

Right to Data Portability You have the right to receive your personal data in a structured, commonly used, machine-readable format, and to transmit it to another data controller where technically feasible.

Right to Object You have the right to object to processing of your personal data based on our legitimate interests. You also have an absolute right to object to your data being processed for direct marketing purposes.

Rights Related to Automated Decision-Making You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects on you.

Right to Withdraw Consent Where we process your data based on consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal.

7.2 How to Exercise Your Rights

To exercise any of the rights listed above, please contact us at support@achebecampus.com with the subject line "Data Subject Request" and a description of the right you wish to exercise. We will respond within 30 days of receiving your request. In complex or multiple cases, we may extend this period by a further two months and will notify you accordingly.

We may need to verify your identity before processing your request. We will not charge a fee for reasonable requests but reserve the right to charge a reasonable administrative fee for requests that are manifestly unfounded or excessive.

7.3 Marketing Communications

You may opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link in any marketing email or by updating your notification preferences in your account settings. Please note that even after opting out of marketing communications, you will continue to receive transactional and service-related emails (such as purchase receipts, account notices, and security alerts), as these are necessary to the operation of your account.

7.4 Cookies

You can manage your cookie preferences through our cookie settings tool or through your browser settings. Please note that disabling certain cookies may affect the functionality of the Service. See Section 10 for more detail.

8. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

The following general principles guide our retention decisions:

Account data is retained for as long as your account remains active. If you delete your account, we will delete or anonymise your personal data within 90 days, subject to the exceptions below.
Transaction and financial records are retained for a minimum of 7 years to comply with tax and accounting legal obligations.
Content you have posted in shared community spaces may persist after account deletion in certain circumstances (for example, where it forms part of a thread that other users rely on), though it will be anonymised where possible.
Legal and compliance records may be retained for longer periods where required by law, regulatory guidance, or to defend or establish legal claims.
Backups may retain data for a limited additional period beyond standard deletion cycles, but this data will not be actively used.

When personal data is no longer required, we securely delete or anonymise it in accordance with our internal data retention and disposal procedures.

9. Children's Privacy

The Service is not directed to children under 13 years of age (or under 16 in the European Economic Area and United Kingdom). We do not knowingly collect, use, or disclose personal information from children under these ages.

If we become aware that we have inadvertently collected personal information from a child under the applicable minimum age, we will take immediate steps to delete that information and terminate the relevant account.

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us immediately at support@achebecampus.com and we will act promptly.

10. Cookies and Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They serve various functions, including remembering your preferences, keeping you logged in, and helping us understand how the Service is being used.

10.2 Types of Cookies We Use

Strictly Necessary Cookies These cookies are essential for the Service to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled.

Performance and Analytics Cookies These cookies collect information about how users interact with the Service, such as which pages are visited most often and whether users receive error messages. The data is used in aggregate form to improve the Service.

Functional Cookies These cookies allow the Service to remember your choices (such as language or region preferences) and provide a more personalised experience.

Marketing and Targeting Cookies These cookies may be set by us or our advertising partners to deliver relevant promotions and measure the effectiveness of marketing campaigns. They track your browsing activity across sites.

10.3 Managing Cookies

You can manage or disable cookies through:

Our cookie preference centre, accessible via the cookie banner when you first visit the Service
Your browser settings, where you can block or delete cookies

Please be aware that blocking certain cookies may impair the functionality of the Service, including the ability to log in or access paid content.

11. Third-Party Links and Integrations

The Service may contain links to third-party websites, or integrate with external tools and services (such as video platforms, payment processors, or social networks). These third parties have their own privacy policies, which we encourage you to review. Achebe Campus is not responsible for the privacy practices or content of any third-party service, and this Privacy Policy does not apply to those services.

12. Creator Data Responsibilities

Where creators collect personal data about their community members through the Achebe Campus platform (for example, membership information, engagement data, or direct messages), creators may act as independent data controllers or data processors for that data, depending on the context and jurisdiction.

Creators are responsible for:

Complying with applicable data protection laws in relation to their members' data
Providing any required notices to their members about data collection and use
Ensuring they have a lawful basis for any processing they carry out
Keeping member data confidential and not using it for purposes outside of community management on Achebe Campus

Achebe Campus may provide creators with data processing agreements where required under GDPR or UK GDPR. Please contact support@achebecampus.com for more information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

Post the updated policy on the Service with the revised "Last updated" date
Send you an email notification to the address associated with your account
Where required by law, obtain your renewed consent

We encourage you to review this policy periodically. Your continued use of the Service after the effective date of any changes constitutes your acceptance of the updated policy.

14. Contact Us and Supervisory Authority

Data Controller Contact

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

Achebe Campus Privacy Team Email: support@achebecampus.com Subject line: "Privacy Enquiry"

Data Protection Officer

For matters specifically relating to your rights under GDPR or UK GDPR, you may contact our Data Protection Officer:

Email: support@achebecampus.com Subject line: "DPO — Data Subject Request"

We aim to respond to all privacy-related enquiries within 30 days.

Right to Lodge a Complaint

UK users: If you are based in the United Kingdom and believe your data protection rights have been violated, you have the right to lodge a complaint with the Information Commissioner's Office (ICO): Website: ico.org.uk Helpline: 0303 123 1113

EEA users: If you are based in the European Economic Area, you have the right to lodge a complaint with the supervisory authority in your country of residence or place of work.

We would, however, appreciate the opportunity to address your concerns before you approach a supervisory authority, and encourage you to contact us in the first instance.

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