Privacy Policy

Last updated: 31 May 2026 · Compliant with GDPR (EU General Data Protection Regulation) and NDPR (Nigeria Data Protection Regulation)

1. Who We Are

Tueri Educational Services ("we", "us", "our") is a Nigerian educational technology company. We operate the following platforms:

• Tueri Prep (prep.tueri.ng) — AI-powered exam preparation for WAEC, JAMB, and NECO
• CareerSparks (careersparks.ng) — Online educational psychology and career guidance

Our registered address is Lagos, Nigeria. Our Data Protection Officer is Tolu Ogunremi. For data protection inquiries, contact tolu.ogunremi@gmail.com or privacy@tueri.ng.

2. Data Controller

Tueri Educational Services is the data controller for all personal data collected through our platforms. We are responsible for determining how and why your personal data is processed.

3. What Personal Data We Collect

We collect and process the following categories of personal data:

3.1 Information You Provide

• Account data: full name, email address, phone number, and password (stored as a bcrypt hash)
• Profile data: parent/guardian email addresses, teacher email addresses
• Academic data: subjects enrolled, exam types selected, exam scores, performance analytics, and topic-level accuracy
• Payment data: virtual account references, transaction records (we do NOT store credit/debit card numbers)
• Communications: any messages sent to us via email or WhatsApp

3.2 Information Collected Automatically

• Usage data: pages visited, features used, time spent, exam attempts
• Device data: IP address, browser type, operating system, device identifiers
• Cookie data: authentication tokens (JWT), session identifiers, preference settings

4. Legal Basis for Processing (GDPR Article 6 + NDPR)

We process your personal data under the following legal bases:

• Consent (Article 6(1)(a)): You give explicit consent during registration by accepting this Privacy Policy. You may withdraw consent at any time by contacting us.
• Contractual necessity (Article 6(1)(b)): Processing is necessary to provide our exam preparation services, including scoring, performance tracking, and AI-powered analysis.
• Legal obligation (Article 6(1)(c)): We retain certain transaction records to comply with Nigerian financial regulations.
• Legitimate interests (Article 6(1)(f)): We process usage data to improve our services, detect fraud, and ensure platform security.

5. How We Use Your Data

• To create and manage your account
• To deliver exam practice materials, score your results, and generate AI-powered explanations and readiness reports
• To process payments, including voucher redemptions and bank transfer verifications
• To send automatic progress reports to designated parent and teacher email addresses
• To send service-related communications (password resets, payment confirmations)
• To improve our AI models and question bank
• To comply with legal and regulatory obligations

6. Data Sharing and Third Parties

We do NOT sell your personal data. We share data only with these categories of recipients:

• Service providers: Fidelity Bank (virtual account processing), Termii (SMS/OTP delivery), DeepSeek (AI answer generation — anonymous question text only, no personal identifiers)
• Parent/guardian and teachers: Progress reports are sent to email addresses you designate during enrollment
• Legal authorities: When required by applicable law or court order

7. Data Retention

We retain your personal data for as long as your account is active. Upon account deletion, we retain:

• Anonymised exam scores: Retained for platform analytics (no longer linked to your identity)
• Transaction records: Retained for 6 years to comply with Nigerian financial regulations
• All other personal data: Permanently deleted within 30 days of deletion request

8. Your Rights

Under GDPR and NDPR, you have the following rights:

• Right of access (Art 15): Request a copy of all personal data we hold about you
• Right to rectification (Art 16): Correct inaccurate or incomplete data
• Right to erasure / "Right to be forgotten" (Art 17): Request deletion of your data
• Right to restrict processing (Art 18): Limit how we use your data
• Right to data portability (Art 20): Receive your data in a machine-readable format
• Right to object (Art 21): Object to processing based on legitimate interests
• Right to withdraw consent: Withdraw consent at any time without affecting the lawfulness of prior processing
• Right to lodge a complaint: File a complaint with the Nigeria Data Protection Commission (NDPC) or your local data protection authority

To exercise any of these rights, email privacy@tueri.ng. We will respond within 30 days.

9. Consent Withdrawal

You may withdraw your consent to processing at any time by deleting your account through the Settings page or by contacting us. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

10. Security Measures

We implement appropriate technical and organisational measures to protect your personal data:

• Passwords are hashed using bcrypt (industry-standard, salted)
• Authentication uses JWT tokens with 30-day expiry
• All traffic is encrypted via HTTPS/TLS
• Database is stored in an encrypted volume with restricted access
• API endpoints are rate-limited to prevent abuse
• We perform regular security audits and dependency updates

11. Children's Privacy

Our services are designed for secondary school students preparing for WAEC, JAMB, and NECO examinations. We do not knowingly collect data from children under 13 without parental consent. If you believe a child under 13 has provided us with personal data, please contact us immediately.

12. International Data Transfers

Your data is stored on servers located in Nigeria and the European Economic Area (EEA). When we transfer data to third-party processors (e.g., DeepSeek for AI analysis), we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) where required by GDPR.

13. Cookies

We use the following cookies and similar technologies:

• Essential cookies: JWT authentication token, session identifiers. Required for platform functionality.
• Preference cookies: Theme selection (light/dark), color scheme preference, visited status.
• Analytics cookies: Anonymous page view tracking for platform improvement.

You can manage cookie preferences through your browser settings. Disabling essential cookies will prevent platform functionality.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email and by updating the "Last updated" date at the top of this policy. Continued use of our services after such changes constitutes acceptance of the updated policy.

15. Contact

For any questions, concerns, or to exercise your data protection rights:

• Email: privacy@tueri.ng
• WhatsApp: +234 801 234 5678
• Address: Lagos, Nigeria

Our Data Protection Officer is Tolu Ogunremi and can be reached at tolu.ogunremi@gmail.com or dpo@tueri.ng.

You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or your local data protection supervisory authority.