Legal

Privacy Policy

Aug 4, 2026

1. Introduction

Zuwa Platforms Ltd ("we", "us", or "our") understands that your privacy is important to you. This Privacy Policy sets out how we collect, use, store, and disclose your personal information in connection with your use of the Zuwa platform, accessible at zuwa.so, including all associated web pages, features, and services (collectively, the "Platform").

This Privacy Policy applies to all users of the Platform, including creators, students, visitors, and any other person who interacts with us through the Platform or otherwise.

By accessing or using the Platform, you consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy and as otherwise permitted or required by applicable Nigerian law, including the Nigeria Data Protection Regulation (NDPR) 2019 and guidelines issued by the National Information Technology Development Agency (NITDA).

Our Terms of Use, available at zuwa.so/terms-of-use, also apply to your use of the Platform and should be read alongside this Policy.

We may update this Privacy Policy from time to time by publishing a revised version on the Platform. We will notify you of material changes.

2. Collection of Personal Information

2.1 Circumstances of Collection

We may collect personal information about you when:

• you register for an account on the Platform as a creator or student;
• you create or enrol in a class, cohort, or programme on the Platform;
• you make or receive a payment through the Platform;
• you upload content, materials, recordings, or communications to the Platform;
• you connect a third-party service to your account (such as Zoom, Google Meet, WhatsApp, or Google Calendar);
• you contact us by any method including email, the Platform's messaging system, WhatsApp, or telephone;
• you subscribe to our waitlist, mailing list, or marketing communications;
• you participate in surveys, feedback sessions, or research we conduct;
• you apply for a position with us; or
• you otherwise interact with us or the Platform in any way.

2.2 Collection via Third-Party Services

Where you authorise the Platform to connect to or integrate with a third-party service - such as Zoom for live class delivery, Paystack or Flutterwave for payments, WhatsApp Business for notifications, or Google Calendar for scheduling - we may collect information from those services, including account details, transaction metadata, and communication data necessary to deliver the relevant Platform feature.

We may also collect information about you from third parties in the context of recruitment, such as from recruitment agencies, referees, or background check providers.

We may combine information we hold about you with information obtained from third parties and our service providers as part of our normal operations.

2.3 Automated Collection

We collect certain information automatically when you use the Platform, including:

• your IP address and approximate location;
• the date, time, and duration of your sessions on the Platform;
• the features and pages you access and your navigation patterns;
• the device, browser, and operating system you use to access the Platform;
• crash reports and performance data.

Cookies. We use cookies and similar tracking technologies to collect information about your use of the Platform. Cookies are small files placed on your device that help us recognise you, remember your preferences, and improve your experience. You may configure your browser to reject cookies, but doing so may affect the availability or functionality of certain Platform features.

2.4 Analytics

We use analytics tools - including third-party providers such as Google Analytics and Vercel Analytics - to understand how users interact with the Platform, to measure performance, and to improve our services. For information on how Google uses data collected through its analytics tools, please visit google.com/policies/privacy/partners.

2.5 Third-Party Websites and Services

The Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies before providing any personal information to them.

3. Types of Personal Information We Collect

The personal information we collect will vary depending on how you use the Platform, but may include:

• Identity information — your full name, username, profile photo, and date of birth;
• Contact information — email address, phone number, and physical address;
• Account credentials — username and encrypted password;
• Creator information — professional bio, credentials, qualifications, bank account details for payout, KYC verification documents, and class content;
• Student information — enrolment history, class attendance records, assignment submissions, quiz scores, and certificates of completion;
• Payment information — transaction history, payment method type, and payout records. We do not store raw card data - this is handled by Paystack and Flutterwave;
• Communication content — messages sent through the Platform's community and direct messaging features, feedback submitted, and support requests;
• Usage data — how you interact with the Platform as described in section 2.3;
• Device and technical data — IP address, browser type, operating system, and session information.

Where you apply for a role with us, we may also collect sensitive information such as identification documents, employment history, and reference information.

4. How We Use Your Personal Information

4.1 General Use

We collect and use your personal information for purposes connected with operating and improving the Platform, complying with applicable Nigerian law, and running our business. We do not use your personal information for purposes that are unrelated to these goals or that you would not reasonably expect.

4.2 Specific Purposes

Without limiting the above, we use your personal information for the following purposes:

• to create and manage your account, authenticate your identity, and administer your settings and permissions;
• to deliver the features and functionality of the Platform, including class scheduling, live class delivery, student management, payment processing, and community features;
• to process payments and payouts, including verifying creator identity for CBN compliance purposes;
• to facilitate integrations with third-party services that you enable in your account settings;
• to send you transactional communications — including class reminders, payment receipts, enrolment confirmations, and account security alerts — via email, in-app notifications, and WhatsApp;
• to improve, maintain, and develop Platform features, including testing and enhancing algorithms and AI-powered features;
• to personalise your experience on the Platform based on your usage history and preferences;
• to conduct analytics, research, and reporting to understand how the Platform is used and how it can be improved;
• to send you marketing and promotional communications about Zuwa features, events, and offers, where you have consented to receive them or where we have a legitimate interest in doing so — you may opt out at any time;
• to monitor, detect, and prevent fraud, abuse, security incidents, and violations of our Terms of Use;
• to create de-identified or anonymised data that we may use for any purpose; and
• to comply with our legal, regulatory, and tax obligations under Nigerian law and any other applicable jurisdiction.

4.3 Use for AI Feature Improvement

Where Zuwa operates AI-powered features — including cohort setup assistance, scheduling suggestions, and content recommendations — we may use platform usage data to improve those features. We will only use personal information to improve AI features for your individual experience. Any broader AI model improvement uses only de-identified data. You may opt out of this broader use in your account settings.

5. Sharing Your Personal Information

5.1 Within Our Group

We may share your personal information with related entities within the Zuwa Platforms Ltd corporate group for operational, administrative, and compliance purposes.

5.2 Third-Party Service Providers

We share personal information with third-party service providers who assist us in operating the Platform. These include:

• Payment processors — Paystack and Flutterwave, for processing student payments and creator payouts;
• Video conferencing providers — Zoom and Google Meet, for live class delivery;
• Cloud hosting and storage — Vercel and Cloudflare, for Platform hosting and content delivery;
• Database providers — Supabase, for secure data storage;
• Notification providers — Termii and Resend, for WhatsApp and email communications;
• Analytics providers — Google Analytics and Vercel Analytics, for usage data and Platform performance;
• Error monitoring tools — Sentry, for tracking and resolving technical issues.

We select service providers based on their security standards and require them to handle your personal information only for the purposes we specify.

5.3 Other Creators or Students

Certain information is visible to other users of the Platform by design. Creator profiles — including name, bio, credentials, and class listings — are publicly visible on the marketplace. Student names and progress data are visible to the creator of any class they are enrolled in. Please consider what information you include in your public profile.

5.4 Legal and Regulatory Disclosures

We may disclose your personal information where required or permitted by Nigerian law, including in response to lawful requests from regulatory authorities such as NITDA, the CBN, or law enforcement agencies.

5.5 Business Transfers

We may disclose your personal information to parties involved in a merger, acquisition, restructure, or sale of all or substantially all of our assets, including during any due diligence process, subject to confidentiality obligations on the receiving party.

5.6 International Transfers

Some of our third-party service providers are located outside Nigeria, including in the United States and the United Kingdom. Where your personal information is transferred outside Nigeria, we take steps to ensure it is handled with appropriate protections. By using the Platform, you consent to these transfers as described in this Policy.

6. Your Rights and Choices

Under the NDPR and applicable Nigerian law, you have the following rights in relation to your personal information:

• Right of access — you may request a copy of the personal information we hold about you;
• Right to correction — you may request that we correct inaccurate or incomplete personal information;
• Right to erasure — you may request that we delete your personal information, subject to our legal retention obligations;
• Right to data portability — you may request that we provide your personal information in a portable, machine-readable format where technically feasible;
• Right to withdraw consent — where we rely on your consent to process your personal information, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal;
• Right to opt out of marketing — you may opt out of marketing communications at any time by clicking the unsubscribe link in any email we send you, or by contacting us at info@zuwa.so.

To exercise any of these rights, please contact us at info@zuwa.so. We will respond to your request within 30 days. We may need to verify your identity before processing your request.

7. Data Retention

We retain your personal information for as long as necessary to provide the Platform and fulfil the purposes described in this Policy, including:

• Account information — retained for the duration of your account and for a reasonable period after account closure;
• Transaction and financial records — retained for a minimum of 7 years in compliance with Nigerian financial regulations;
• Class recordings — stored for 12 months from the session date by default, unless you delete them earlier;
• Personal data after account deletion — deleted within 30 days of account closure, except where longer retention is required by law;
• Marketing data — retained until you opt out or withdraw consent.

When we no longer require your personal information, we take reasonable steps to securely destroy or de-identify it.

8. Security

We take the security of your personal information seriously. We implement appropriate technical and organisational measures to protect your data from unauthorised access, loss, misuse, alteration, or disclosure. These include:

• TLS encryption for all data transmitted between your device and our servers;
• bcrypt hashing for all user passwords — we never store plain-text passwords;
• role-based access controls limiting internal access to personal data;
• regular security reviews and monitoring;
• selection of third-party providers based on their security certifications and practices.

However, no security system is impenetrable. We cannot guarantee the absolute security of your information and are not liable for unauthorised access that results from circumstances beyond our reasonable control.

We encourage you to use a strong, unique password for your Zuwa account and to enable multi-factor authentication where available.

9. Children

The Platform is not intended for use by persons under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a person under 18, please contact us at info@zuwa.so and we will delete it promptly.

10. Cookies and Tracking Preferences

You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling cookies may affect the functionality of certain features on the Platform. We do not currently respond to browser Do Not Track signals, but you may contact us to discuss your preferences.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Where we make material changes, we will notify you by email or via a prominent notice on the Platform before the changes take effect. The updated Policy will be effective as of the date stated at the top of the document.

12. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our handling of your personal information, please contact us:

Zuwa Platforms Ltd
Abuja, Nigeria
Email: info@zuwa.so
Website: zuwa.so

If you make a complaint, we will acknowledge it within 5 business days and endeavour to resolve it within 30 days. If you are not satisfied with our response, you may escalate your complaint to the National Information Technology Development Agency (NITDA) at nitda.gov.ng or by contacting their data protection unit directly.