Privacy Policy

This Privacy Policy explains how SchoolItPropa ("SIP," "we," "us," or "our") collects, uses, shares, and protects personal data through the SchoolItPropa platform, including its desktop application and its Staff, Parent, and Student mobile applications (together, the "Service").

This Policy is written to comply with the Nigeria Data Protection Act, 2023 (“NDPA”), the NDPA General Application and Implementation Directive, 2025 (“GAID”), and the Child’s Rights Act 2003, as SIP currently operates exclusively within Nigeria. [PLACEHOLDER: this Policy will need material revision before SIP operates in any other country — do not reuse this document for other jurisdictions without legal review specific to that jurisdiction.]

Data Controller / Data Processor: [PLACEHOLDER — LEGAL ENTITY NAME], a company registered in Nigeria under RC number [PLACEHOLDER], with its registered address at [PLACEHOLDER ADDRESS].

For most personal data processed through the Service, SIP acts as a Data Processor, and the school using SIP ("the School") is the Data Controller — the School determines what student, staff, and parent data is collected and why, and SIP processes it on the School’s behalf and instructions, under a written Data Processing Agreement between SIP and the School.

[PLACEHOLDER: confirm this controller/processor characterization with legal counsel — some processing described below, such as the cross-school Social Feed and Cross-School Benchmarking, may make SIP a joint controller or independent controller instead, which changes SIP’s own direct obligations.]

Data Protection Officer contact: [PLACEHOLDER EMAIL] / [PLACEHOLDER PHONE].

• Schools and School Administrators — who register the School, its staff, and its students on the Service.
• Teachers and Non-Teaching Staff — who use the SIP desktop application and/or the SIP Staff mobile application.
• Parents and Guardians — who use the SIP Parent mobile application to view and respond to their child’s records.
• Students — who use the SIP Student mobile application, where enabled by their School.

4.1 Data collected about Schools, Staff, and Admins

• Account and identity data: name, email, phone number, role, job title, photograph (optional).
• Employment data: department, subjects taught, class assignments, employment start date, duties.
• Attendance and location data: sign-in/sign-out times, and — for staff using geofenced attendance in the Staff mobile app — location data limited to detecting entry/exit from a defined school-radius geofence. SIP does not continuously track staff location outside this geofencing purpose.
• Class punctuality data: for Schools on a plan that enables it, whether and when a teacher started a scheduled class period (derived from the same class-reminder signal used to nudge teachers) — used for admin-facing compliance visibility, not continuous monitoring.
• Performance and administrative data: workload records, lesson notes, scheme-of-work records, disciplinary and duty records relating to staff conduct where applicable.
• Voice input (optional feature): where a Staff member uses voice dictation for attendance or lesson notes, audio is transcribed on-device using local speech-to-text — the recording and its transcription are never sent to any third-party cloud speech-to-text service.
• Device and technical data: device type, app version, crash logs, IP address.

4.2 Data collected about Students

• Identity and enrollment data: name, date of birth, class, admission details, photograph (optional), guardian/parent contact information, provided by the School at registration.
• Academic data: attendance records, grades, exam and Computer-Based Test (CBT) results, assignments, terminal/mid-term/weekly reports, awards, and disciplinary records.
• Student mobile app (Learning Centre) data, where the Student app is enabled by the School and by parental consent: content viewed (images, videos, facts, books), reading and pronunciation feature usage, and words or passages looked up via the highlight-to-search feature. This data is used only to personalize recommended content to the student’s class and age level, and is never shared outside SIP and the student’s own School.
• SIP does not knowingly collect data directly from a student through any channel that bypasses the School’s registration and parental consent process described in Section 6.

4.3 Data collected about Parents/Guardians

• Identity and contact data: name, email, phone number, relationship to student(s).
• Activity data: records viewed, report acknowledgements, and feedback submitted through the Parent app.
• Payment data: where a Parent uses the Service to pay School fees or SIP subscription fees, payment card and transaction details are collected and processed directly by Paystack, SIP’s third-party payment processor, under Paystack’s own security and compliance standards. SIP does not store full card numbers and does not hold or take custody of payment funds at any point — Paystack processes each payment and remits it directly to the intended recipient (the School, for school fees; SIP, for subscription fees). SIP receives only limited transaction metadata from Paystack (amount, status, reference number, payer name) necessary to reflect the payment in the Parent’s and School’s records.

4.4 Data underlying cross-school features

• Cross-School Benchmarking (opt-in only): School-level aggregate statistics (e.g. average grade by subject and class level) are shared only for Schools that have explicitly opted in, are aggregated across a minimum number of students to prevent identification of any individual, and never include any single student’s name or record.
• Social Feed (school events): where a School chooses to publish content to the shared, cross-school Social Feed (e.g. sports days, graduations, competitions), that content — which may include photographs or names of students, staff, or events — is visible to users at other Schools on the Service. Only a School's own Staff/Admin accounts can author or publish Social Feed content — students and parents cannot post — and a post only becomes visible once published by that School.

[PLACEHOLDER: finalize and document the exact audience scope for a published Social Feed post (e.g. whether it is visible to every School on the Service, or a narrower set) before this section is finalized — see open product questions noted separately. Schools remain responsible for ensuring they have appropriate consent, per Section 6, before posting content that identifies a student to this cross-school audience.]

Under the NDPA, SIP and Schools rely on the following legal bases, depending on the data and purpose:

• Consent: for processing any Student’s personal data, and for any processing that is not necessary for the School’s core educational functions (e.g. the Learning Centre, Cross-School Benchmarking opt-in, Social Feed posts identifying a student). See Section 6 for how consent for Student data is obtained.
• Contractual necessity / legitimate interest: for staff, admin, and School account data necessary to provide the core Service to the School under its agreement with SIP.
• Legal obligation: where SIP or a School must retain or disclose data to comply with Nigerian law.

SIP treats every Student as a child for the purposes of the NDPA and the Child’s Rights Act 2003, regardless of age, and applies the following consent process before any Student’s personal data is processed through the Service:

• The School obtains explicit, specific, written parental or guardian consent as part of its own student enrollment/admission process, using consent language that specifically names SchoolItPropa (SIP) and describes the categories of data and purposes set out in Section 4.2.
• This consent must be obtained, and a record of it retained by the School, before the School registers the Student on the Service — including before any Computer-Based Test (CBT), assignment, or record is created for that Student — not merely before the Student’s own first use of a mobile app.
• Schools already using the Service before this consent process was established are responsible for retroactively obtaining and documenting this consent for all currently enrolled Students as soon as reasonably possible.
• A parent or guardian may withdraw consent at any time by contacting the School or SIP directly (see Section 12). Withdrawal does not affect the lawfulness of processing carried out before withdrawal, but SIP will, upon confirmed withdrawal, cease further processing of that Student’s data for the purposes affected and will delete or anonymize the data in line with Section 10, except where retention is required by law.

See the School Enrollment Consent Clause — the exact wording provided to Schools for this consent, downloadable for insertion into a School’s own enrollment form.

[PLACEHOLDER — CRITICAL LEGAL REVIEW ITEM: whether a School may validly obtain NDPA-compliant parental consent on SIP’s behalf through its own enrollment paperwork, and the exact wording required for that consent to be specific and valid under GAID, has not been confirmed by qualified Nigerian legal counsel. Do not treat this section as settled until that review is complete.]

• To provide, maintain, and improve the Service, including offline sync between the desktop application and SIP’s servers.
• To generate reports, analytics, and dashboards for Schools (e.g. attendance trends, the Early-Warning risk indicators, School Health Reports).
• To power optional AI-assisted features (question generation and grading assistance) — see Section 8.
• To send notifications relevant to a user’s role (e.g. attendance alerts, report availability, announcements).
• To detect, investigate, and prevent misuse, fraud, or security incidents.

SIP offers optional AI-assisted question generation, grading, and writing-assistance tools, available to Schools on a qualifying subscription plan (see Pricing). These tools process assignment and exam content to generate suggested questions or grading feedback. AI-generated grading is always reviewable and may be overridden by a teacher, and is flagged for human review whenever the system’s confidence is low, or whenever AI grading is unavailable for the School’s plan.

SIP’s AI-assisted grading and question-generation features currently use OpenAI’s API (model: gpt-4o-mini) as the default AI provider. When OpenAI is used, the text of a student’s essay or short-answer exam response is transmitted to OpenAI’s API solely to generate a suggested score and feedback for teacher review — the student’s name, class, or other identifying information is not included in that request. Question-generation and writing-assistance features transmit only teacher-supplied topic/lesson content, not student data. SIP does not use Student data from these features to train any general-purpose or third-party AI model.

[PLACEHOLDER: confirm and disclose OpenAI’s current API data-retention and no-training terms (these can change over time and should be cited/linked at time of publication, not assumed permanently true), and confirm whether a Data Processing Addendum with OpenAI is in place, before this section is finalized — this is a required disclosure, not optional detail. Also disclose here if/when a self-hosted, on-premises AI provider option becomes available for Schools that prefer no data to leave their own infrastructure.]

SIP does not sell personal data. Data is shared only as follows:

• With the Student’s own School and the School’s authorized staff, as necessary to provide the Service.
• With a Parent/Guardian, limited to their own linked child’s(ren’s) data, once the parent-child relationship has been verified by the School (see Section 6).
• In aggregated, anonymized form, for Cross-School Benchmarking, only for Schools that have opted in, and only where the aggregate group is large enough that no individual Student can reasonably be identified.
• Where a School publishes content to the cross-school Social Feed, as described in Section 4.4.
• With Paystack, SIP’s payment processor, solely to process a payment a Parent initiates through the Service. SIP does not receive or store full card details.
• With other service providers who process data on SIP’s behalf under written data protection terms (e.g. cloud hosting, email/notification delivery, and — when a School enables AI-assisted grading — OpenAI, per Section 8).
• Where required by Nigerian law, regulation, or valid legal process.

[PLACEHOLDER: link or otherwise disclose Paystack’s own privacy policy to users at the point of payment, per NDPA transparency requirements, and list every specific sub-processor and its location here before publication — required under NDPA accountability obligations.]

SIP retains personal data for as long as the relevant School account remains active, and for a further period afterward as required for legal, regulatory, or legitimate record-keeping purposes. On confirmed withdrawal of consent, School account closure, or a valid deletion request, SIP will delete or irreversibly anonymize the relevant data within [PLACEHOLDER: X] days, except where retention is legally required.

[PLACEHOLDER: specify exact retention periods per data category — e.g. academic records, disciplinary records, attendance logs, voice/transcription data — in consultation with the School and legal counsel.]

SIP applies technical and organizational safeguards appropriate to the sensitivity of the data processed, including encryption of data in transit, AES-256 encrypted local backups (for the offline-first desktop application), and access controls limiting data visibility to a user’s own role and School.

[PLACEHOLDER: state where data is hosted/stored (server location/country). If any hosting, backup, or sub-processor infrastructure — including OpenAI, per Section 8 — is located outside Nigeria, this constitutes a cross-border transfer under the NDPA and requires an applicable legal basis — an NDPC adequacy decision, an approved Cross-Border Data Transfer Instrument, or another lawful basis such as explicit consent — which must be confirmed with legal counsel and disclosed here before this Policy is published.]

Under the NDPA, data subjects (and, for a Student, their parent or guardian exercising rights on the Student’s behalf) have the right to:

• Access the personal data SIP or the School holds about them.
• Request correction of inaccurate or incomplete data.
• Request erasure of data no longer necessary for the purpose it was collected, subject to legal retention requirements.
• Withdraw consent at any time, where processing is based on consent.
• Receive their data in a structured, machine-readable format and request its transfer, where technically possible.
• Object to certain processing, including automated decision-making, where applicable.

Requests should be directed to the School in the first instance, or to SIP directly at [PLACEHOLDER EMAIL]. SIP will respond within the timeframe required by the NDPA. You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated.

The Student mobile application’s Learning Centre contains only content curated and approved by School staff. Students cannot post their own content, and there is no open commenting or direct messaging between students within the Service.

SIP may update this Policy from time to time. Material changes affecting Student data or the legal basis for processing will be communicated to Schools in advance, and Schools are responsible for notifying parents/guardians as appropriate.

[PLACEHOLDER — LEGAL ENTITY NAME]

[PLACEHOLDER ADDRESS]

Email: [PLACEHOLDER EMAIL] | Phone: [PLACEHOLDER PHONE]

Nigeria Data Protection Commission (NDPC): [PLACEHOLDER — insert current NDPC complaint contact/URL at time of publication].