Privacy Policy - Dominie

Privacy Policy

This Privacy Policy explains how DOMINIE LIMITED, an education technology and online tutoring company operating through dominie.org, collects, uses, stores, shares and protects personal information when you use the Dominie website, platform, learning-management systems, applications, services and related communications (collectively, the “Platform”).

In this Privacy Policy, “Dominie,” “we,” “us” and “our” refer to DOMINIE LIMITED. “You” and “your” refer to learners, parents or guardians, tutors, independent service providers, schools, corporate clients, visitors and other individuals who interact with Dominie.

This Privacy Policy should be read together with Dominie's Master Terms of Use and Service, Child Safeguarding Policy, Acceptable Use Policy, Tutor and Independent Digital Service Provider Agreement and other applicable Platform policies.

1. Our Commitment to Privacy

Dominie respects your privacy and is committed to handling personal information responsibly, transparently and securely.
We process personal information in accordance with applicable data-protection laws, including the Nigeria Data Protection Act and other laws that may apply depending on your location.

2. Personal Information We Collect

We may collect the following categories of personal information.

2.1 Identity and contact information. This may include:
- full name;
- username;
- email address;
- telephone number;
- postal or residential address;
- date of birth;
- nationality;
- profile photograph;
- identification information; and
- emergency-contact information where appropriate.

2.2 Account and profile information. This may include:
- account credentials;
- profile biography;
- learner level;
- subjects and interests;
- learning goals;
- tutor qualifications;
- certificates;
- teaching experience;
- professional history;
- references;
- introduction videos;
- availability;
- portfolio information;
- ratings and reviews; and
- other information submitted during registration or onboarding.

2.3 Learner and educational information. For learners, we may collect:
- course and lesson information;
- learning preferences;
- academic level;
- assignments;
- assessment results;
- attendance;
- progress records;
- feedback;
- communication history;
- accessibility requirements; and
- information reasonably necessary to provide educational services.

2.4 Parent or guardian information Where a learner is a child or minor, we may collect information about the parent or legal guardian, including:
- name;
- contact details;
- relationship to the learner;
- consent records;
- payment information;
- communication preferences; and
- information required to verify parental or guardian authority.

2.5 Payment and transaction information. We may collect:
- billing details;
- transaction history;
- payment status;
- invoices;
- refunds;
- chargebacks;
- payout information for tutors;
- bank or payment-account details; and
- information supplied by payment providers.
Dominie may not directly store complete payment-card details where payment processing is handled by a third-party payment provider.

2.6 Technical and usage information. When you use the Platform, we may collect:
- IP address;
- device type;
- browser type;
- operating system;
- device identifiers;
- login records;
- access times;
- pages and features used;
- approximate location;
- referral information;
- error logs;
- security events; and
- other technical information generated through Platform use.

2.7 Communications and support information. We may collect information contained in:
- emails;
- support requests;
- tutor-learner communications;
- complaints;
- feedback;
- survey responses;
- reports;
- safeguarding concerns; and
- other communications with Dominie.

2.8 Verification and safeguarding information. Where reasonably necessary, we may collect:
- identity-verification information;
- qualification records;
- reference information;
- professional-history information;
- safeguarding-check information;
- age-verification information;
- parental-consent records; and
- information relating to suspected fraud, abuse, misconduct or safety concerns.

2.9 Information from third parties. We may receive information from:
- parents or guardians;
- tutors;
- schools;
- corporate clients;
- payment providers;
- identity-verification providers;
- safeguarding or background-check providers;
- analytics providers;
- referral partners;
- publicly available sources; and
- other authorised persons or organisations.

3. Children’s Personal Information

Dominie provides educational services that may be used by children.
Where a learner is a child or minor, we may require appropriate involvement and consent from a parent or legal guardian, depending on the learner's age, the service provided and the applicable legal requirements.
We may collect and use children's personal information only for legitimate purposes, including:
- creating and managing an account;
- providing lessons and educational services;
- monitoring learning progress;
- communicating with parents or guardians;
- safeguarding and protecting children;
- preventing fraud and misuse;
- processing payments; and
- complying with legal obligations.
We do not knowingly sell children's personal information.
Parents or guardians may contact us to request access to, correction of or deletion of a child's personal information, subject to applicable law and legitimate retention requirements.

4. How We Collect Personal Information

We collect personal information:
- directly from you;
- from a parent or guardian;
- from a tutor or service provider;
- when you create or use an account;
- when you book or attend a lesson;
- when you make or receive a payment;
- when you communicate with us;
- through cookies and similar technologies;
- from third-party service providers; and
- from other lawful sources.

5. Purposes for Using Personal Information

We may use personal information to:
- create and manage accounts;
- provide tutoring, learning and digital services;
- match learners with tutors;
- schedule and administer lessons;
- process payments, refunds and payouts;
- verify identities, qualifications and information;
- communicate about bookings, lessons and Platform matters;
- provide customer support;
- monitor learning progress;
- improve educational services;
- personalise Platform content;
- maintain tutor and learner profiles;
- administer ratings and reviews;
- protect children and vulnerable persons;
- investigate complaints and safeguarding concerns;
- detect and prevent fraud, abuse and security incidents;
- enforce our agreements and policies;
- maintain Platform security;
- conduct analytics and service improvement;
- send service-related communications;
- send marketing communications where permitted;
- comply with legal and regulatory obligations; and
- establish, exercise or defend legal claims.

6. Lawful Bases for Processing

Depending on the circumstances, Dominie may process personal information on the basis of:
- your consent;
- performance of a contract or steps taken at your request before entering into a contract;
- compliance with a legal obligation;
- protection of vital interests;
- performance of a task carried out in the public interest where applicable; and
- our legitimate interests, provided those interests do not override your rights and freedoms.
Where we rely on consent, you may withdraw consent at any time, although withdrawal will not affect processing already carried out lawfully before withdrawal.

7. Marketing Communications

We may send information about Dominie services, educational opportunities, Platform updates, events or promotions where permitted by law.
You may opt out of marketing communications by:
- using the unsubscribe link in the relevant message;
- changing your account preferences; or
- contacting us.
You may continue to receive essential service communications, including account, security, payment, booking and safeguarding messages.

8. Cookies and Similar Technologies

Dominie may use cookies, pixels, local storage and similar technologies to:
- keep you signed in;
- remember preferences;
- maintain Platform functionality;
- understand how the Platform is used;
- improve performance;
- detect fraud and security threats;
- measure marketing effectiveness; and
- personalise content where permitted.
You may adjust cookie settings through your browser or available Platform controls. Disabling certain cookies may affect Platform functionality.

9. Sharing Personal Information

We may share personal information with:
- tutors and learners where necessary to provide booked services;
- parents or guardians where appropriate;
- schools and corporate clients where authorised;
- payment processors;
- hosting and cloud-service providers;
- customer-support providers;
- identity-verification providers;
- safeguarding and background-check providers;
- analytics and technology providers;
- communications providers;
- professional advisers;
- insurers;
- auditors;
- regulators;
- law-enforcement authorities; and
- courts or other competent authorities.
We require service providers that process personal information on our behalf to apply appropriate confidentiality and security measures.
We do not sell personal information as a commercial product.

10. Tutor and Learner Information

To facilitate lessons and Platform services, we may share limited information between tutors and learners, such as:
- name;
- profile photograph;
- biography;
- qualifications;
- subjects;
- availability;
- lesson details;
- learning goals;
- relevant communication information; and
- information reasonably necessary for service delivery.
Tutors must use learner information only for authorised Dominie-related purposes and must comply with applicable data-protection and safeguarding requirements.
Learners and parents or guardians must also use tutor information responsibly and must not misuse, publish or distribute it without permission.

11. International Data Transfers

Some service providers or recipients may be located outside Nigeria or outside the country where you live.
Where personal information is transferred internationally, Dominie will take reasonable steps to ensure that the transfer is lawful and that appropriate safeguards are in place, as required by applicable law.

12. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:
- provide services;
- maintain business and financial records;
- comply with legal obligations;
- resolve disputes;
- enforce agreements;
- prevent fraud;
- protect Platform security; and
- establish, exercise or defend legal claims.
Retention periods may vary depending on the type of information, the purpose of processing and applicable legal requirements.
When personal information is no longer required, we may securely delete, anonymise or otherwise dispose of it.

13. Data Security

Dominie uses reasonable technical and organisational measures to protect personal information against:
- unauthorised access;
- accidental loss;
- destruction;
- alteration;
- disclosure;
- misuse; and
- other unlawful processing.
Security measures may include:
- access controls;
- authentication procedures;
- encryption where appropriate;
- secure hosting;
- monitoring;
- backups;
- staff confidentiality obligations; and
- incident-response procedures.
No method of transmission or storage is completely secure. You are responsible for keeping your account credentials confidential and notifying us promptly if you suspect unauthorised access.

14. Data Breaches and Security Incidents

If Dominie becomes aware of a personal-data breach, we will assess and respond to it in accordance with applicable law.
Where legally required, we may notify affected individuals, regulators or other relevant authorities.
If you become aware of unauthorised access, loss, disclosure, phishing, malware or another security incident involving Dominie information, you should notify us promptly.

15. Your Privacy Rights

Subject to applicable law, you may have the right to:
- request access to personal information we hold about you;
- request correction of inaccurate or incomplete information;
- request deletion of personal information;
- request restriction of processing;
- object to certain processing;
- withdraw consent;
- request data portability where applicable;
- object to direct marketing;
- request information about how your data is used; and
- lodge a complaint with a competent data-protection authority.
These rights may be subject to lawful exceptions, including legal retention requirements, security needs, fraud prevention and the rights of others.

16. How to Exercise Your Rights

To exercise a privacy right or ask a privacy question, contact Dominie using the contact details provided on the Platform or through our official support channels.
We may need to verify your identity before responding to a request.
We aim to respond within the period required by applicable law. If a request is complex or subject to a lawful exception, we may explain the reason for any delay, refusal or limitation.

17. Account Deletion

You may request closure or deletion of your account.
Account deletion may not immediately remove all information where we are required or permitted to retain it for:
- legal compliance;
- payment and accounting records;
- fraud prevention;
- dispute resolution;
- safeguarding;
- security;
- enforcement of agreements; or
- other legitimate purposes.
Some information may be anonymised rather than deleted.

18. Third-party Links and Services

The Platform may contain links to third-party websites, applications or services.
Dominie is not responsible for the privacy practices, content or security of third parties. You should review the privacy policies of third-party services before providing personal information.

19. Recording and Monitoring

Dominie may monitor or record certain Platform activities for legitimate purposes, including:
- safeguarding;
- quality assurance;
- training;
- dispute resolution;
- fraud prevention;
- security;
- technical support; and
- compliance with legal obligations.
Where recording is used, Dominie will provide appropriate notice and apply applicable data-protection requirements.
Users must not secretly record, publish or distribute lessons or communications involving other individuals without appropriate authorisation.

20. Automated Decision-making and Profiling

Dominie may use automated tools for purposes such as:
- fraud detection;
- security monitoring;
- service personalisation;
- tutor-learner matching;
- analytics; and
- Platform administration.
Where applicable law provides rights concerning solely automated decisions that produce legal or similarly significant effects, Dominie will provide appropriate information and safeguards.

21. Professional and Safeguarding Information

Dominie may process information relating to tutor qualifications, professional history, complaints, safeguarding concerns, misconduct, fraud or security incidents where reasonably necessary to:
- protect learners and tutors;
- verify suitability;
- maintain Platform integrity;
- investigate complaints;
- comply with legal obligations; and
- prevent harm.
Such information will be handled confidentially and shared only where reasonably necessary and lawful.

22. Your Responsibilities

You must:
- provide accurate information;
- keep account information current;
- protect your login credentials;
- use the Platform lawfully;
- respect the privacy of other users;
- avoid sharing personal information unnecessarily;
- report suspected security or safeguarding incidents; and
- comply with Dominie's policies.
You must not attempt to access another person's account or use personal information for unauthorised purposes.

23. Privacy of Tutors and Service Providers

Tutors and independent service providers acknowledge that Dominie may process information relating to:
- identity;
- qualifications;
- professional experience;
- references;
- verification;
- payment and tax matters;
- availability;
- performance;
- ratings and reviews;
- communications;
- complaints;
- safeguarding; and
- Platform activity.
This information may be used to administer onboarding, provide services, process payments, maintain profiles, protect learners and comply with legal obligations.

24. Privacy of Parents and Guardians

Parents and guardians acknowledge that Dominie may process their information to:
- verify authority and consent;
- manage a child's account;
- communicate about lessons;
- process payments;
- monitor safeguarding;
- provide support; and
- comply with legal obligations.
Parents and guardians should ensure that information supplied about themselves and their children is accurate and current.

25. Data Protection Contact

For privacy questions, requests or complaints, contact Dominie through the official contact details published on dominie.org or through the Platform support channel.
Where required by applicable law, Dominie may appoint or designate a data-protection officer or privacy contact to handle privacy matters.

26. Changes to this Privacy Policy

Dominie may update this Privacy Policy where reasonably necessary because of:
- changes in law;
- regulatory guidance;
- Platform changes;
- new services;
- security developments;
- business operations; or
- technological developments.
Material changes will be communicated through an appropriate channel where reasonably practicable.
The updated version will state its effective date. Your continued use of the Platform after the effective date of an updated policy may constitute acceptance where permitted by law.

27. Governing Law

This Privacy Policy shall principally be governed by the laws of the Federal Republic of Nigeria, subject to any mandatory privacy or data-protection laws applicable to you.
Where you are located outside Nigeria, you may have additional rights under the laws of your jurisdiction.

28. Complaints

If you have a concern about how Dominie handles personal information, please contact us first so that we can investigate and attempt to resolve the matter.
You may also have the right to complain to the relevant data-protection authority or regulator in your jurisdiction.

29. Acceptance

By using the Dominie Platform, creating an account, submitting information or accepting a Dominie agreement, you acknowledge that you have read and understood this Privacy Policy.
Where consent is required, Dominie will request it through an appropriate mechanism.

Effective Date: 17 September 2026
DOMINIE LIMITED