DATA PRIVACY POLICY

The Learning Core Company is committed to safeguarding the personal data of all applicants and participants of the MTN ICT and Business Skills Training Phase 7. This Data Privacy Policy outlines the lawful basis for collecting, processing, storing, and disclosing personal information in accordance with the Nigeria Data Protection Act (NDPA) 2023 and other applicable regulations.

1. Personal Data We Collect

In connection with the application, verification, enrollment, and participation in the Program, we may collect and process the following categories of personal data:

  • Full name and contact information (email, phone number, address)

  • Gender and date of birth

  • Business and professional information

  • State of residence

  • Identity documents or verification details (where applicable)

  • Assessment data, responses, attendance records, and training outputs

  • Any additional information reasonably required for program administration

2. Legal Basis for Processing

We process your personal data on the following lawful grounds:

  • Consent voluntarily provided by you

  • Legitimate interests in administering and managing the Program

  • Contractual necessity for program participation

  • Compliance obligations required by MTN or regulatory bodies

3. Purpose of Data Processing

Your data will be used strictly for the following purposes:

  • Screening and eligibility verification

  • Program enrollment, administration, and communication

  • Monitoring, evaluation, and reporting to MTN

  • Improving program delivery, curriculum, and participant experience

  • Compliance with audit, verification, and funding requirements

  • Generating anonymized analytics and impact reports

The Learning Core Company will not sell, rent, or use your data for unrelated marketing or commercial purposes.

4. Data Sharing and Disclosure

Your personal data may be shared with the following authorized parties ONLY:

  • MTN Foundation and its designated compliance, monitoring, and reporting units

  • Program facilitators, trainers, and administrative staff under confidentiality obligations

  • Independent auditors or evaluators engaged for program assessment

  • Regulatory authorities where legally required

All parties receiving your data are bound by confidentiality and data protection obligations.

5. Data Storage and Security

Heels & Tech adopts appropriate technical and organizational measures to protect your data from unauthorized access, loss, misuse, alteration, or disclosure.

Data is stored securely on controlled systems and retained only for the duration required to fulfill program purposes and lawful obligations.

6. Your Data Rights

Under applicable laws, you have the right to:

  • Request access to your personal data

  • Request correction of inaccurate or incomplete data

  • Withdraw your consent at any time

  • Request deletion of your data, subject to legal or contractual limitations

  • Object to certain forms of processing

  • Lodge a complaint with the Nigeria Data Protection Commission (NDPC)

7. Consent

By submitting your information and participating in the Program, you acknowledge that you have read and understood this Data Privacy Policy and consent to the collection, processing, and disclosure of your personal data for the purposes stated herein.