Privacy Policy

1. Introduction

This Privacy Policy explains how Rhymes Homes and Partners Limited (“we”, “our”, or “us”), operating the Examyra platform, collects, uses, stores, and protects personal information from users of our online educational services. Examyra is an AI-powered examination preparation platform designed to assist students in preparing for JAMB, WAEC, NECO, and related academic examinations through personalized, data-driven learning.

By accessing or using Examyra, you agree to the collection and use of your information as described in this Policy. If you do not agree with any provision of this Policy, you should discontinue use of the platform immediately.

This Policy applies to all users of Examyra, including students, parents or guardians who register on behalf of minors, and any other persons who interact with our platform or services.

2. Data Controller Information

The data controller responsible for your personal information under this Policy is:

• Company Name: Rhymes Homes and Partners Limited
• Registration Number: RC 941172
• Trading Name: Examyra
• Registered Address: Wuse Zone 5, Abuja, Federal Capital Territory, Nigeria
• Email Address: legal@examyra.com
• Website: www.examyra.com

3. Information We Collect

3.1 Information You Provide Directly

When you register for an account or use our services, we may collect the following categories of personal data:

• Full name and date of birth
• Email address and phone number
• Account type selected at registration (student or parent/guardian)
• School name, class level, and examination targets (e.g., JAMB, WAEC, NECO)
• Username and account password (stored in encrypted form)
• Payment information, including billing name and transaction references (card numbers are processed directly by our payment processor and are not stored on our servers)
• Profile photograph, where voluntarily uploaded
• Communications you send to our support team

3.2 Information Collected Automatically

When you use the Examyra platform, certain technical data is collected automatically, including:

• Device type, operating system, and browser version
• IP address and approximate geographic location
• Pages visited, features used, and time spent on each section of the platform
• Learning performance data such as quiz scores, test results, topic completion rates, and response accuracy
• Session logs and error reports

3.3 Information from Third Parties

Where you choose to sign in or register using a third-party service such as Google, we receive basic profile information from that service, including your name and email address, in accordance with the permissions you grant at the time of connection.

4. How We Use Your Information

We use the personal information we collect for the following purposes:

• To create and manage your user account on Examyra
• To deliver personalized learning content, practice tests, and AI-generated study recommendations based on your performance data
• To generate progress reports for parent and guardian accounts linked to a student account, including weekly email summaries of subjects, scores, and study activity
• To process subscription payments and issue receipts or invoices
• To send important service communications such as account confirmations, password resets, subscription renewals, and platform updates
• To respond to your inquiries, complaints, or requests submitted through our support channels
• To improve the Examyra platform by analyzing usage patterns and identifying areas for enhancement
• To detect fraudulent activity and enforce our Terms of Service
• To comply with applicable Nigerian laws and the requirements of our licensed payment processing partners

We do not use your personal information for automated decision-making that produces legal or similarly significant effects without appropriate safeguards.

5. AI Processing of Learning Data

Examyra uses artificial intelligence, including large language models such as Claude AI, to generate practice questions, explanations for incorrect answers, and personalized study plans. To deliver these features, learning performance data (such as topic scores, response patterns, and study history) may be processed by our AI service providers.

Data shared with AI service providers is limited to what is necessary to generate educational content and recommendations. We do not send your name, contact details, or payment information to AI providers for content generation purposes. AI service providers are contractually restricted from using your data for their own purposes, and generated content is delivered back to your account within the Examyra platform.

6. Legal Basis for Processing

We process your personal information on the following legal bases:

• Contractual necessity: Processing is required to deliver the services you have subscribed to and to fulfil our obligations under our Terms of Service.
• Legitimate interests: Processing is necessary for the operation, security, and improvement of our platform, provided that your rights and interests are not overridden.
• Legal compliance: Processing is required to meet obligations under Nigerian law, including the Nigeria Data Protection Act 2023 (NDPA) and applicable regulations issued by the Nigeria Data Protection Commission (NDPC).
• Consent: Where we rely on your consent, such as for optional marketing communications, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing and Disclosure

7.1 Third-Party Service Providers

We share personal data with carefully selected third-party service providers who assist us in operating the Examyra platform. These include:

• Payment processor: Paystack, our approved payment gateway, for the secure processing of subscription payments by card, bank transfer, and USSD. Paystack operates under its own privacy and data security framework and is PCI-DSS compliant. We may engage additional licensed payment processors from time to time, and any such processor will be subject to equivalent standards.
• AI service providers, for the generation of practice questions, explanations, and study plans as described in Section 5
• Cloud hosting and infrastructure providers, for the storage and delivery of our platform services
• Analytics providers, for understanding platform usage patterns in aggregated or pseudonymised form
• Email and communications service providers, for sending service-related messages, including weekly parent progress reports

All third-party providers are required to process your data only for the purposes for which it was shared and to maintain appropriate security measures.

7.2 Legal Disclosure

We may disclose your personal information where required to do so by law, court order, or regulatory authority, including in response to lawful requests from the Nigerian Communications Commission, the NDPC, or any competent law enforcement body.

7.3 Business Transfers

In the event that Rhymes Homes and Partners Limited undergoes a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you by email and through a prominent notice on our platform prior to any such transfer becoming effective.

7.4 No Sale of Personal Data

We do not sell, rent, or trade your personal information to any third party for their own marketing or commercial purposes.

8. Data Retention

We retain your personal information for as long as your account remains active or as required to provide you with our services. After your account is closed or your subscription lapses, we retain certain data for up to three years to comply with financial record-keeping requirements and to handle any subsequent disputes or legal obligations.

Learning performance data may be retained in anonymized form beyond this period for research and platform improvement purposes.

You may request deletion of your account and associated personal data at any time by contacting us at legal@examyra.com. Requests will be processed within 30 days, subject to any applicable legal retention obligations.

9. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and our servers
• Encryption of sensitive stored data, including passwords and payment references
• Role-based access controls limiting staff access to personal data
• Regular security assessments and vulnerability testing
• Incident response procedures for managing potential data breaches

While we take reasonable steps to protect your data, no method of electronic storage or internet transmission is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us promptly if you suspect any unauthorized access to your account.

10. Children's Privacy

Examyra is designed for secondary school students preparing for national examinations. Users under the age of 18 must obtain the consent of a parent or legal guardian before registering. Where a parent or guardian registers on behalf of a minor through a parent account, we treat the guardian as the account holder and direct all account and billing communications accordingly.

We do not knowingly collect personal data from children under 13 years of age. If we become aware that a child under 13 has provided personal data without appropriate consent, we will delete that information promptly.

Parents and guardians may contact us at legal@examyra.com to review, correct, or request deletion of personal data associated with a minor's account.

11. Your Rights

Under the Nigeria Data Protection Act 2023, you have the following rights regarding your personal data:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data, subject to our legal retention obligations.
• Right to restrict processing: You may request that we limit how we use your data in certain circumstances.
• Right to data portability: You may request a copy of your data in a structured, machine-readable format.
• Right to object: You may object to the processing of your data where we rely on legitimate interests as our legal basis.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time.

To exercise any of these rights, please contact us at legal@examyra.com. We will respond to all requests within 30 days. We may require verification of your identity before processing your request.

12. Cookies and Tracking Technologies

Examyra uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small data files stored on your device that help us recognize your session, remember your preferences, and analyze platform usage.

You may control cookie settings through your browser preferences. Please note that disabling certain cookies may affect the functionality of the Examyra platform. A detailed Cookie Policy is available on our website.

13. Third-Party Links

Our platform may contain links to third-party websites or resources that are not operated by us. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies before providing any personal information.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, applicable law, or industry standards. When we make material changes, we will notify you by email or through a prominent notice on the platform at least 14 days before the changes take effect.

Your continued use of Examyra following the effective date of any revision constitutes your acceptance of the updated Policy.

15. Contact and Complaints

For any questions, concerns, or requests relating to this Privacy Policy, please contact our Data Protection Officer:

If you are not satisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at www.ndpc.gov.ng.