IMPORTANT PRIVACY INFORMATION

Xemofal Limited, a company registered under the laws of the Republic of Cyprus, having its registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus, will be the controller of your personal data.

We collect data you give us voluntarily (for example, email address). We also collect data automatically (for example, your IP address).

1. Data you give us:
   ‍
   If you decide to make a purchase on the Website, we will ask you to provide your email address, name, phone number and state. Also, we will ask you to provide your answers to the quiz.
   ‍
   We will use your name to show it in your profile. We will use your email address to enrol you in the course, send marketing emails with our product and resolve support cases. Likewise, we will use your phone number and state to resolve support/sales cases.
2. Data we collect automatically:
   
   2.1. Data about how you found us
   
   We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped/clicked on our ad).
   
   2.2. Device and Location data
   
   We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID. We also record the ads in our Website with which you interact (and the Internet links to which those ads lead).
   
   2.3. Usage data
   
   We record how you interact with our Service. For example, we log what pages you have viewed, the features and content you interact with, how often you use the Website, how long you are on the Website, your purchases.
   
   2.4. Advertising IDs
   
   We collect your Apple Identifier for Advertising (“IDFA”), Identifier for Vendor (“IDFV”) or Google Advertising ID (“AAID”) (depending on the operating system of your device) when you access our Website from a mobile device. You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).
   
   2.5. Transaction data
   
   When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.
   
   2.6. Cookies
   
   A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.
   
   Cookies are used, in particular, to automatically recognize you the next time you visit our website. As a result, the information, which you have earlier entered in certain fields on the website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.
   

We process your personal data:

1. To provide our Service
   ‍
   This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
   
   To host personal data and enable our Service to operate and be distributed we use Thinkific, which is a learning management system. Privacy Policy.
2. To provide you with customer support
   
   We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about, the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.
   
3. To communicate with you regarding your use of our Service
   
   We communicate with you, for example, by emails. These may include for example, emails with information about the Service. To opt out of receiving emails, you need to follow the instructions in the footer of the emails.
   
4. To research and analyze your use of the Service
   
   This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.
   
   We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people visit our Website, how often users make purchases, and other interactions. Lean more about Facebook’s approach to data from its Privacy Policy.
   
5. To send you marketing communications
   
   We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Website. We may show you advertisements on our Website, and send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.
   
6. To personalize our ads
   
   We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our Website, you might see ads of our products in your Facebook’s feed.
   
   ‍How to opt out or influence personalized advertising
   IOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads. 
   
   ‍Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here.
   
   ‍macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads. 
   
   ‍Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity. If you have other Windows version, please follow the steps here
   
   ‍To learn even more about how to affect advertising choices on various devices, please look at the information available here.
   
   In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
   
   Network Advertising Initiative – http://optout.networkadvertising.org/
   ‍Digital Advertising Alliance – http://optout.aboutads.info/
   ‍Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
   ‍Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
   ‍DAA AppChoices page – http://www.aboutads.info/appchoices‍
   
   ‍Browsers: It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.
   
   ‍Cookie settings in Internet Explorer
   ‍Cookie settings in Firefox
   ‍Cookie settings in Chrome
   ‍Cookie settings in Safari web and iOS
   
   ‍Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
   
   ‍We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.
   
   We use Facebook pixel on the Website. Facebook pixel is a code placed on the Website collecting data that helps us track conversions from Facebook ads, build targeted audience and remarket to people who have taken some action on the Website (for example, purchased a meal plan).
   
   We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Service (for example, visited certain sections of the Website). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.
   
   Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.
   
   ‍Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our Website (for example, show our ads to users who have made a purchase). Some other examples of events that may be used for tailoring ads include, in particular, visiting our Website. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
   
   ‍TikTok Ads is the service provided by TikTok that can deliver ads to its users. The ads can be tailored to specific categories of users (for instance, based on their geographical location). TikTok’s Privacy Policy.
   
   We also use Twitter Ads provided by Twitter to deliver advertising. Twitter Ads allows us to choose specific audiences based on geographic areas or user’s interests. As a result, we may ask Twitter to deliver our ads to certain list of users. Twitter allows you to opt-out its internet-based advertising. Privacy Policy.
   
   
7. To process your payments
   
   We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made.
   
   We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
   
8. To enforce our Terms and Conditions of Use and to prevent and combat fraud
   
   We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
   
9. To comply with legal obligations
   
   We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
   

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.

We process your personal data under the following legal bases:

1. to perform our contract with you;
   ‍
   Under this legal basis we:
   a. Provide our Service (in accordance with our Terms and Conditions of Use)
   b. Provide you with customer support
   c. Communicate with you regarding your use of our Service
   d. Process your payments
2. for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
   
   ‍We rely on legitimate interests:
   
   a. to communicate with you regarding your use of our Service
   This includes, for example, sending you email to notify you that we have released a new product or reminding to finish a course. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.
   
   b. to research and analyze your use of the Service
   Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website easier and more enjoyable, or to introduce and test new features).
   
   c. to send you marketing communications
   The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.
   
   d. to personalize our ads
   The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
   
   e. to enforce our Terms and Conditions of Use and to prevent and combat fraud
   Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
   
3. to comply with legal obligations.

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

1. Service providers
   ‍
   We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
   a. cloud storage providers (Thinkific)
   b. data analytics providers (Facebook)
   c. measurement partners
   d. marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, TikTok, Twitter)
   e. payment service providers (Solid)
   
2. Law enforcement agencies and other public authorities
   
   ‍We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
   
3. Third parties as part of a merger or acquisition
   
   ‍As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
   

To be in control of your personal data, you have the following rights:

‍Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website.
‍Deleting your personal data. You can request erasure of your personal data as permitted by law.
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
‍Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.
‍Additional information for EEA-based users:If you are based in the EEA, you have the following rights in addition to the above:
‍The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
‍The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request to us as described below.
To exercise any of your privacy rights, please send a request to edu.contact@corp.legit.ng (for Nigerian users), edu.contact@tuko.co.ke (for Kenyan users).

We do not knowingly process personal data from individuals under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Except as otherwise stipulated in this Privacy Policy, this Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at
‍edu.contact@corp.legit.ng (for Nigerian users),
‍edu.contact@tuko.co.ke (for Kenyan users),
service@xemofal.com (other).

Effective as of: 15 March 2024