Data Protection and Privacy Notice

IWA is a digital character-development platform providing learning experiences involving stories, choices, reflection, practice and related activities.

Proposed Data Controller: Steward Financials Limited.

Registered Address: Dr Obelawo Avenue, Zone E1, Ofatedo Osogbo.

Privacy/Data Protection Contact: IT Audit Team, IWA.

Privacy Email: ITAudit@useiwa.com.

IWA technology and platform operations are provided through Steward Financials Limited.

IWA content, including curriculum, stories, characters, learning materials and related intellectual property, is owned by Peaches and Peaches Concepts.

Students using IWA; Parents/Guardians registering or managing a Student; Teachers and school administrators; Corporate/school users; IWA administrators and support personnel; visitors to the IWA website; and other individuals who provide personal data to IWA.

Where a Student is a child, IWA applies additional safeguards appropriate to children’s personal data.

Parent/Guardian information may include first name and surname, email address, phone number where required, gender where required, account credentials, subscription/payment-related information, support requests and communications, and information relating to the Student linked to the account.

Student information may include first name and surname, age/date-of-birth information where required, gender, Student account/access credentials, school or corporate association, learning activity and module participation, choices, reflections and responses, practice activities, developmental observations and feedback, reinforcement activities, and safeguarding information where a safeguarding concern is raised.

Technical information may include IP address, device information, browser information, login/authentication information, security/access logs, usage and interaction information, cookies and similar technologies.

We seek to collect only information that is adequate, relevant and reasonably necessary for the purposes for which it is processed.

We may use personal data to create and manage accounts and Student profiles; provide access to IWA; connect Students with authorised Parent/Guardians or schools; deliver and save learning, reflection and developmental activity; provide feedback and reinforcement; administer subscriptions and payments; provide support; secure the platform and prevent misuse; respond to safeguarding concerns; improve performance and functionality; meet legal and regulatory obligations; and communicate important service information.

Depending on the processing activity, IWA may rely on lawful bases recognised under applicable data protection law, including consent, performance of a contract, legal obligation, legitimate interests where permitted, vital interests, or another lawful basis available under applicable law.

The lawful basis will depend on what data is being processed and why. Where processing relies on consent, the relevant person may have the right to withdraw that consent, subject to applicable legal limitations and the nature of the processing.

IWA is designed to support Students, including children. Because children’s personal data requires particular care, IWA applies additional safeguards to its collection and use.

Where IWA relies on consent to process a child’s personal data, the Parent/Guardian must provide the appropriate authorisation in accordance with applicable law. Privacy information presented directly to children should be written in language they can reasonably understand.

IWA does not use a Student’s learning activity to assign an overall character score, rank, pass/fail status or permanent character label. Developmental information supports learning and reflection rather than judging a child’s overall character.

IWA may collect answers to scenarios, selected choices, reflections, learning and practice activities, observations, reinforcement activities and module completion information.

This information may be used to understand participation and support the Student’s developmental journey. IWA does not use it to create a numerical character score or rank Students against one another.

IWA may use artificial intelligence technologies to support certain aspects of the learning experience, such as reviewing a Student’s written reflection against predefined learning criteria and providing appropriate feedback.

AI-assisted processing supports the learning experience and does not determine whether a Student has good or bad character. Where automated processing has significant implications, IWA will apply safeguards required by applicable data protection law.

Personal data may be shared with authorised Parent/Guardians, schools, teachers and administrators; technology, infrastructure, payment, transaction, email, communications, security, hosting and platform-support providers; professional advisers; regulatory or law-enforcement bodies where legally required; and other service providers acting on our behalf under appropriate safeguards.

We do not sell Students’ personal data. Access to Student information is role-based and should be limited to authorised persons for legitimate purposes.

Some providers supporting IWA may process personal data outside Nigeria. Where personal data is transferred across borders, IWA will apply safeguards and lawful transfer mechanisms required under applicable data protection law.

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, disclosure, loss, destruction, alteration, misuse and other unlawful or unauthorised processing.

No electronic system can guarantee absolute security. We therefore continuously review and improve our security measures.

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, to provide our services, meet legal or regulatory obligations, resolve disputes, maintain security, or enforce applicable agreements.

Retention periods may vary depending on the type of information, purpose, account status, legal or regulatory requirements and legitimate operational requirements.

Subject to applicable law, you may have rights to request access, correction, deletion in appropriate circumstances, restriction, objection, withdrawal of consent where consent is the lawful basis, data portability where applicable, and to raise a concern or complaint.

To exercise your rights or ask a question about your personal data, contact ITAudit@useiwa.com or write to IT Audit Team, IWA, Dr Obelawo Avenue, Zone E1, Ofatedo Osogbo.

We may need to verify your identity before responding, particularly where a request concerns another person’s personal data or a child’s information. We may also need to verify authority to act on a Student’s behalf.

Safeguarding concerns are handled separately from ordinary developmental observations. Access is restricted to the person who raised the concern and appropriately authorised recipients under IWA’s safeguarding procedures.

Safeguarding information will not be used simply as a character score, ranking or permanent character label.

IWA may use cookies and similar technologies necessary to operate, secure and improve the website and application. Where non-essential technologies require consent, users will be given appropriate choices.

A separate Cookie Notice should explain the categories used, their purposes and available controls.

We may update this notice to reflect changes in services, technology, data-processing activities, applicable law or regulatory guidance. The latest version will be published on useiwa.com with its effective or updated date.

We encourage you to contact IWA first so that we can investigate and attempt to resolve your concern.

Where you are not satisfied with our response, you may have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or visit www.ndpc.gov.ng, or contact another competent data protection authority, as applicable.