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GLEEN – Privacy Policy

Effective date: 01 October, 2025
Operator / Data Controller: Nexoris Technologies Ltd (“we”, “us”, “our”)
Product: Gamified Learning & Exam Excellence Networks (GLEEN) – mobile app and website
Support: support@mygleen.com • Privacy: privacy@mygleen.com
Registered address: [To be decided]

This policy explains what data we collect, why we collect it, how we use it, who we share it with, how long we keep it, your rights, and how to contact us in line with the Nigeria Data Protection Act, 2023 (NDPA).

Using GLEEN means you agree to this Privacy Policy and our Terms of Use. If you do not agree, please don’t use GLEEN.

1) The basics

  • What is “Personal Data”? Any information that can identify you directly or indirectly (e.g., name, email, phone, device ID, exam preferences, activity logs).

     
  • Who controls your data? Nexoris Technologies Ltd is the Data Controller for the GLEEN app and website.

     
  • Who can use GLEEN? Users 15+. If you are under 18, you confirm you have parent/guardian consent. GLEEN does not accept public teacher sign-ups; only in-house GLEEN teachers run classes.

2) What we collect

We collect the minimum data needed to run a learning app safely and well:

A. Account & profile

  • Name, username, email, phone (if provided), password (hashed), age band, school/class (if applicable), avatar/handle.

B. Learning activity

  • Subjects you study, quiz attempts, scores, streaks, badges/XP, challenges joined, leaderboard position, time-on-task, completion rates.

C. Device & app data

  • App version, device model/OS, language, crash logs, diagnostics, IP address, general location (city/state level), mobile advertising ID (if enabled).

D. Live classes (GLEEN teachers only)

  • Session metadata (date/time, class ID), your join/leave time, chat messages, Q&A, audio/video if a session is recorded (you’ll see notices).

     
  • Microphone/camera only when you enable them.

E. Parent/guardian link (optional)

  • If a student links a parent/guardian, we process the relationship (emails/IDs) and share light progress data (e.g., study time, quiz stats, streaks—not private messages).

F. Payments & redemptions

  • When you subscribe via Apple/Google, those stores process your payment; we receive non-card metadata (e.g., success/failure, plan, expiry).

     
  • For XP redemptions (e.g., airtime), we process phone number, network, redemption amount, and delivery status with our telecom/payment partners.

G. Support & safety

  • Messages you send to support, reports of abuse, content moderation flags, and decisions taken.

H. Cookies & similar tech (web)

  • Session cookies to keep you logged in, preference cookies, basic analytics cookies. In-app we may use mobile identifiers for analytics/notifications.

We do not intentionally collect special/sensitive categories (e.g., health, religion) and we don’t sell personal data.

3) Why we collect it (lawful bases)

Under the NDPA, we rely on these lawful bases:

  1. Contract: To create your account, run quizzes, award XP, show progress, process subscriptions/redemptions, and provide support.

     
  2. Legitimate interests: To keep the platform secure, prevent cheating/fraud, improve performance, fix crashes, and understand feature usage.

     
  3. Consent: For push marketing, certain analytics, parent linking, and class recordings where required. You can withdraw consent at any time in settings or by emailing us.

     
  4. Legal obligation: To keep records we must keep, respond to lawful requests, manage tax/compliance.

     
  5. Vital interests/Public interest: Only if needed to protect someone’s life/safety or where the law requires.

What happens if you don’t provide data? Some features will not work (e.g., no account without email/phone, no XP airtime without a phone number, no class participation without mic/camera permission).

4) How we use your data

  • Run the app: accounts, quizzes, mocks, streaks, leaderboards, XP, redemptions (airtime/subscription), notifications, parent view (if linked).

     
  • Live classes: let you join, moderate safety, record where applicable (for quality, safety, and replay).

     
  • Improve GLEEN: analytics, crash logs, A/B tests, content quality checks.

     
  • Safety & integrity: detect cheating, “expo” attempts, spam, bullying; limit multiple-account abuse.

     
  • Marketing (optional): send product updates, offers, study tips—you can opt out anytime.

     
  • Legal/compliance: handle requests from regulators/law enforcement when legally required.

Automated decisions & profiling: We use automated logic for leaderboards, content suggestions, and nudges (e.g., “Try a Physics mock”). These do not have legal or similarly significant effects on you. You can ask for a human review of a decision that affects you (see Section 9).

5) Who we share it with

We do not sell data. We share only what’s necessary:

  • Service providers (processors): hosting, analytics, crash reporting, messaging, support tools, content moderation, cloud storage, security.

     
  • App stores & payments: Apple App Store, Google Play (they process your payment under their terms).

     
  • Telecom/payment partners: to deliver airtime or apply subscription from XP. We share phone number, network, and redemption amount only.

     
  • Parents/guardians (optional): if linked, we share light progress data only (no private chat).

     
  • Legal & safety: regulators or law enforcement when required by law or to protect users.

     
  • Business changes: if we undergo a merger, acquisition, or asset sale, your data may transfer under the same protections.

All processors working for us must follow written data-processing terms and keep your data secure.

6) International transfers

GLEEN uses cloud services that may store/process data outside Nigeria. When we transfer data internationally, we apply NDPA-compliant safeguards (e.g., appropriate contracts, technical measures, and ensuring a comparable level of protection). You can contact us for more details of these safeguards.

7) How long we keep data (retention)

We keep data only as long as needed for the purposes above:

  • Account & learning data: while your account is active and for up to 24 months after closure (to allow reactivation, resolve disputes, meet legal obligations).

     
  • Class recordings: typically 90–180 days unless needed longer for safety/legal reasons.

     
  • Support tickets & logs: 12–24 months depending on the issue.

     
  • Billing records: kept as long as the law requires.
    When the period ends, we delete or anonymise the data.

8) Security

We use reasonable administrative, technical, and physical controls, including encryption in transit, limited employee access, access logging, and routine security reviews. No system is 100% secure; if we detect a breach that risks your rights, we’ll follow NDPA breach-notification rules.

9) Your rights (NDPA 2023)

You can exercise these rights at privacy@mygleen.com:

  • Access: ask for a copy of your data.

     
  • Correction: fix inaccurate or incomplete data.

     
  • Deletion: ask us to delete data we no longer need (subject to legal/contractual requirements).

     
  • Restriction: ask us to pause certain processing.

     
  • Portability: request your data in a portable format where applicable.

     
  • Objection: object to processing based on legitimate interests or to direct marketing (we’ll stop marketing immediately).

     
  • Withdraw consent: for any processing based on consent.

     
  • Human review: request review of an automated action that significantly affects you (e.g., an integrity block you think is wrong).

We will respond within the timelines set by the NDPA. We may ask for verification to protect your account.

Complaints: If you’re unhappy with our response, you can contact the Nigeria Data Protection Commission (NDPC). Please reach out to us first; we’ll try to fix it quickly.

10) Children and teens

GLEEN is for users 15+. If you’re under 18, you confirm you have parent/guardian consent. Parent links are optional and can be removed at any time in settings. We do not knowingly collect data from children under 15.

11) Live classes & recordings

  • Classes are hosted only by GLEEN in-house teachers.

     
  • Some sessions may be recorded (audio/video, chat). We’ll show a notice.

     
  • Recordings are used for safety, quality, and replay where offered, then deleted per our retention rules.

     
  • Do not record or share classes without our permission (see Terms of Use).

12) Offline mode & caching

When you’re offline, the app may show a temporary, encrypted cache of lessons/videos.

  • This is not a downloadable file you can keep or share.

     
  • Cached items expire automatically and may refresh or disappear when you reconnect.

     
  • Trying to extract cached content is not allowed (see Terms).

13) Marketing, notifications & preferences

  • Service messages (security alerts, reminders) are necessary; you cannot opt out of those.

     
  • Marketing (product updates, offers, study tips) is optional. You can unsubscribe in the app, by email link, or via device settings for push.

     
  • You can control permissions (camera/mic/notifications) in your device settings.

14) Cookies & analytics (web)

We use cookies to sign you in, remember preferences, and measure what’s working.

  • You can manage cookies via your browser. Blocking some cookies may affect functionality.

     
  • In-app, we may use device identifiers for analytics and notification routing.

15) XP redemptions (important)

  • 1 XP = ₦1 for in-app redemptions only.

     
  • We may share your phone number and network with a telecom/payment partner only to deliver your airtime or apply subscription.

     
  • XP cannot be withdrawn to the bank or converted to cash.

     
  • XP gained via bug, exploit, automation, or policy breach will be removed, and any related redemption may be reversed (see Terms).

16) Changes to this policy

We may update this policy from time to time. If changes are material, we’ll notify you in-app or by email. Using GLEEN after the effective date means you accept the updated policy.

17) Contact us

  • Privacy questions/requests: privacy@mygleen.com
  • General support: support@mygleen.com
  • Safety reports: safety@mygleen.com
  • Legal notices: legal@mygleen.com
  • Address: