Privacy Statement

Introduction

We care about privacy. We believe that privacy is a fundamental right for all individuals. Our clients entrust us with the personal information of their employees and their students. We take the obligations that are attached to this information very seriously. We therefore have a dedicated data privacy program with privacy by design at heart.

Our model of operation is different from that of companies that collect your personal information to monetize such data. We collect and use personal information to allow us to provide our products and services to our clients and end users. In most cases, we do this at the direction of our clients. We do not and will not sell or rent your data to third parties unless this is required in the context of changes to our business structure such as a merger or acquisition.

Who we are. When we refer to “us,” “we,” “our,” or “Smadux” in this Statement, we mean Hi2soft Integrated Solutions. and its affiliates.

This Statement governs all our services that we provide directly to you. Whether you are browsing our websites, receive our newsletters, or use an online trial version of our products, this Statement governs the use of personal information for all our products and services that we provide directly to you.

When your school’s privacy statement/policy governs. If you are an end-user of our client and we are providing our products and services to you on our client’s (your institution’s) behalf, we are considered a ‘data processor.’ In this case your school’s privacy statement governs the use of personal information. Our Privacy Statement does not supersede the terms of any agreements between us and your school (or any other client or third party), nor does it affect the terms of any agreement between you and your school.

Changes to this Statement. From time to time we will need to update this Statement to reflect changes to our products and services, the way we operate, or to meet new legal and regulatory requirements. You will be notify what’s new via email.

How we use your information depends on your relationship with us

What personal information we collect and how we use it will depend on your relationship with us. Please click on the plus symbol to collapse or expand the relevant section below to learn more. The other sections in our Statement apply to all our activities.

Vendors, partners & other types of disclosure

This section provides more information on how we protect your information when we engage vendors, how we share information with our partners, and in which other scenarios we may share your information with third parties.

Vendors

We use vendors to help us provide our products and services to our clients and you or to perform work on our behalf. Where this requires access to personal information, we are responsible for the data privacy practices of the vendors. Our vendors must abide by our strict data privacy and security requirements and instructions. They are not allowed to use personal information they access or receive from us for any other purposes than as needed to carry out their work for us.

Partners

In some countries and regions, our products and services are offered through channel (or reselling) partners. We will share information with them that is necessary for them to offer and provide our products and services to our current and prospective clients.

Other types of disclosures

We will also share your information where required in the following circumstances.

Payments. Where you use our products and services to make a purchase or transaction, we will share your payment and transaction data with banks and other organizations to process the transactions and for fraud detection and prevention or anti-money laundering purposes.

Changes to our business structure. Where permitted by applicable law and by the contracts with our clients, we may disclose your information in the following cases. We will always aim to continue to apply to commitments we make in this Statement in such a case. If this is not possible, we will notify our clients and we will not provide personal information about end users of our clients (including Student Data) without the required agreement of our clients, to a successor entity in the situations described below:

Corporate transactions such as a merger, acquisition, sale of assets, and financing

Bankruptcy, dissolution or reorganization, or in similar transactions or proceedings Steps related to the previous bullet points (for example, due diligence)

Comply with law. We may need to disclose your information to comply with legal or regulatory requirements and to respond to lawful requests, court orders, and legal processes. We will always aim to limit the information we provide as much as possible. Where such disclosures relate to personal information we hold on behalf of our clients, we will defer such requests to our clients where permissible.

Enforce our rights, prevent fraud, and for safety. We may need to disclose your information to protect and defend the rights, property, or safety of us, our clients, or third parties, including enforcing contracts or policies or in connection with investigating and preventing fraud.

De-identified information. We may disclose aggregate or de-identified information that is no longer associated with an identifiable individual for research or to enhance and promote our products and services.

Client engagement & marketing

Client engagement

Managing the client relationship. We are collecting and storing limited personal information about the relevant contacts at our clients for invoicing, notification of product updates and maintenance, and similar purposes.

Marketing

No behavioral advertising to students in our products and services. We do not use or disclose information about students that we collect through the educational products and services we provide on behalf of school for behavioral targeting of advertisements to students. We may place contextual advertising where permitted by our agreement with your school.

Promotion of products and services. We conduct marketing to promote our products and services. This marketing is generally aimed at employee of our current and potential clients and partners. However, we do not restrict activities and events to those audiences when such activities and events benefit instructors and other end users of systems, such as webinars that explain how our products can be used effectively.

Events and webinars. When we conduct or sponsor events and webinars, we will collect information about attendees, such as the session they attend and their contact details, to provide them with relevant product information and other Smadux-related information.

Sharing within Smadux. We may share personal information related to marketing with the relevant Smadux affiliates and departments.

Sharing with partners. In some countries and regions, our products and services are offered through channel (or reselling) partners. We will share the information that is necessary for our partners to promote our products and services to their clients and potential clients. We also work with technology and content partners with whom we may share information such as event attendance if we have permission to do so.

Sharing with vendors. We may use vendors to help us organize and conduct campaigns, events, and other aspects of marketing. We will share with them only the personal information that is necessary and ensure that they are following our strict requirements for vendors.

Marketing preferences and opt-out. Our marketing emails will include a link so that you can change your preferences and opt-out of receiving marketing communications from us. You can do this by clicking on the "Unsubscribe" link or send us email at unsubscribe@smadux.com to unsubscribe.

Online and interest-based advertising on our websites. At times, we use third party advertising tools to collect information about your visits to our websites to serve you targeted advertisements based on your browsing history and interests on other websites and online services or on other devices you may use. We only use these tools on our own websites and not for our products and services. When we are providing our services on behalf of a client, our products and services do not use interest-based advertising tools except as instructed by our clients.

These tools will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You must perform the opt-out on each browser or device you use.

Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

Google Analytics and Advertising on our websites. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting on our own websites. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our websites.

Children’s privacy

We do not knowingly collect any information from children under the age of 13 unless and until the relevant school has provided consent and authorization for a student under 13 to use the products and services and for us to collect information from such student. Where a client institution instructs us to collect personal information from children under the age of 13, we collect, use, process and retain such information solely to provide the educational services on behalf of the client and for the purposes set forth in our agreement with the client. We collect only as much information as is necessary to provide the service and the client may access, delete or withdraw consent for continued processing of the child's information at any time. If you have any questions about reviewing, modifying, or deleting personal information of a child under the age of 13, please contact your school directly.

Please contact us at privacy@smadux.com if you believe we have inadvertently collected personal information from a child under 13 without proper consent. This will allow us to delete such information as soon as possible.

Your rights

You have rights to control how your personal information is used. You may have the right to request access to, rectification of, or erasure of personal information we hold about you. In the Nigeria, you also may have the right to object to or restrict certain types of use of your personal information and request to receive a machine-readable copy of the personal information you have provided to us.

In many of our products, you will be able to access your information as well as change and delete some of the information yourself by logging into your account. If you cannot access, correct, or delete the required information yourself, kindly contact your account officers:

Please remember that many of these rights are not absolute. In some circumstances, we (or your school) are not legally required to comply with your request because of relevant legal exemptions.

In many jurisdictions, you also have the right to lodge a complaint with the local data protection authority. But please contact us first, so we can address your concern.

Contact us

End users of school and technical issues: If you are a user of our products and services we provide on behalf of your school, contact your school first as your school's privacy statement and data privacy practices will determine how Smadux uses personal information on your school's behalf. If you have a technical or support issue, please contact the helpdesk of your school. They will be able to assist.

If you have any questions or concerns about our Privacy Statement or our own data privacy practices, contact us at privacy@smadux.com or write to us at the following address.

Legal Department

Hi2soft Integrated Solutions.

12, Irhirhi Road, Benin City

Last Floor, NG 300125

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