Privacy Policy

1 Identity of Data Controller

The legal data controller responsible for personal information gathered through the platform is:

2 Information We Collect

We collect information you directly provide, information generated through service usage, and technical telemetry necessary for platform security and attribution:

• Identity & Account Information: Your legal name, email address, WhatsApp telephone number, username, and encrypted account authentication passwords.
• Billing & Payment Data: Transaction references, currency selections (NGN or USD), and billing records. Important: All credit card, debit card, and bank checkout transactions are securely handled by PCI-DSS Level 1 certified payment gateways (e.g., PocketFi). We never capture or store raw credit card numbers or CVV codes on our servers.
• Affiliate Payout Credentials: Verified Nigerian bank account details (Bank Name, Account Holder Name, Account Number) required to deposit commission settlements.
• Visitor & Live Chat Interaction Data: Messages, consultation inquiries, and contact identifiers exchanged through our real-time affiliate visitor live chat system.
• Telemetry & Device Information: IP address, device hardware model, browser type, geographic location (country/region), access timestamps, and referring URLs.

3 How We Process Your Data

We process your personal information strictly for legitimate commercial and operational purposes:

• Course Enrollment & DRM Delivery: Providing access credentials to the student learning portal, securing proprietary video assets, and issuing course completion certificates.
• Affiliate Referral Tracking: Calculating sales commissions, applying 30-day attribution cookies, resolving referral credit, and depositing earnings directly to affiliate wallets.
• Payment Verification & Security: Verifying order legitimacy with payment webhooks, eliminating double-spending, and safeguarding accounts against unauthorized withdrawals.
• Transactional Notifications: Sending automated email receipts, password reset links, security verification codes (e.g. for bank account changes), and customer support responses.
• Legal & Regulatory Compliance: Fulfilling accounting, taxation, anti-money laundering (AML), and fraud prevention obligations under Nigerian and international commercial law.

4 Cookies & Attribution Technologies

We employ cookies and secure local storage mechanisms to deliver a seamless user experience and accurate affiliate tracking:

• Strictly Necessary Cookies: Secure HTTP-only authentication session tokens that verify your identity across page reloads.
• Affiliate Referral Cookies: A 30-day attribution cookie (affiliate_id) placed when a prospective student visits via an affiliate's personalized link (e.g., /p/:slug/:username). This guarantees fair and accurate commission payout to the referring partner.
• Third-Party Conversion Pixels: Affiliates who configure ad tracking may deliver Meta Pixel (Facebook) or TikTok Pixel events on their assigned landing pages. These pixels report aggregated conversion events back to the partner's ad manager.

5 Sharing & Disclosure of Information

The Online Mastery Academy Ltd will never sell, rent, lease, or monetize your personal information to third-party data brokers.

We share data exclusively with trusted technical and operational infrastructure providers:

• Payment Processors: Licensed payment institutions (such as PocketFi) to facilitate automated settlements.
• Transactional Communication Providers: Enterprise SMTP services (e.g. Brevo) strictly to transmit operational emails and security tokens.
• Cloud & Hosting Infrastructure: Enterprise cloud servers with isolated databases, daily encrypted backups, and 99.9% uptime architectures.
• Legal Enforcement: When required by lawful court subpoenas, regulatory directives from Nigerian law enforcement authorities, or in the prevention of fraud.

6 Data Security Measures

We employ multi-layered technical, cryptographic, and administrative measures to protect your data against loss, misuse, or unauthorized access:

• Full 256-Bit Transport Layer Security (TLS/SSL) encryption across all endpoints and web sockets.
• Irreversible bcrypt cryptographic hashing with salt rounds for all user passwords.
• Token-based email verification workflows protecting all affiliate withdrawal account and password modifications.
• Hardened server infrastructure protected by firewalls, rate limiting, and automated intrusion monitoring.

7 Your Legal Rights

In accordance with the Nigeria Data Protection Act (NDPA) and applicable global data privacy regulations, you have enforceable rights regarding your data:

• Right to Access: You may request a confirmation and export of the personal data we hold about you.
• Right to Rectification: You can correct or update your personal details directly within your dashboard or by notifying support.
• Right to Erasure ("Right to be Forgotten"): You may request account deletion, subject to statutory record-retention requirements for accounting and tax records.
• Right to Object: You can opt out of any non-essential promotional communications at any time.

8 Contact & Grievance Office

If you have questions, concerns, or requests regarding this Privacy Policy or our data handling practices, please contact our Data Protection and Compliance Desk: