Privacy Policy

1. Introduction

talstack.com is provided by Talstack. Throughout this policy, the terms "we", "us" and "our" refer to Talstack.

At Talstack, we value your privacy and are committed to safeguarding your personal information. All personal data you provide us will be protected and kept confidential among our affiliates, representatives and privies.

This Privacy Policy explains how we collect, use, share and protect your personal data in connection with your relationship with us as a customer or potential customer. It applies to all our customers, potential customers, applicants, partners and every other person we hold information about, and sets out your rights and who you may contact for further information.

You agree to this Privacy Policy by visiting our website and when you use our services. Your use of our services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this Policy.

Our website is hosted in Nigeria and is subject to the laws of the Federal Republic of Nigeria. If you are accessing our website from other jurisdictions, please be advised that you are transferring your personal information to us in Nigeria, and by using our website you are agreeing to the transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of the Federal Republic of Nigeria concerning your use of the website and your agreements with us.

Our website and services are not directed at you if we are prohibited by any law of any jurisdiction from making the information on our website available to you, and is not intended for any use that would be contrary to local law or regulation.

3. Consent

3.1 Where processing of your personal data is based on consent, we shall obtain the requisite consent at the time of collection of the personal information. You consent to the processing of your personal information when you access our website, or use our services, content, features, technologies or functions offered on our website or other digital platforms. You can withdraw your consent at any time, but such withdrawal will not affect the lawfulness of processing based on consent given before its withdrawal.

3.2 Where your personal data is to be processed for a different purpose that is incompatible with the purpose for which it was originally collected, and that was not disclosed to you when you first provided your consent, we will obtain your consent to the new purpose.

4. Age restriction

4.1 You affirm that you are over 18 years old and have the right to contract in your own name, and that you have read the above authorisation and fully understand its contents.

4.2 Individuals under 18 years old are only allowed to sign up for our services or provide us with their information when an adult above the age of 18 is signing contracts in their stead.

5. Data protection principles

The Data Protection Legislation sets out the following principles with which anyone handling personal data must comply. We, our employees, agents, contractors and third-party service providers comply with these principles when collecting or processing your personal data. All personal data must be:

1. processed lawfully, fairly and in a transparent manner in relation to the data subject;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes — further processing for archiving in the public interest, or for scientific, historical or statistical purposes, is not considered incompatible;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
4. accurate and, where necessary, kept up to date — every reasonable step is taken to erase or rectify inaccurate personal data without delay;
5. kept in a form permitting identification of data subjects for no longer than necessary, subject to appropriate safeguards for longer archival, research or statistical retention;
6. processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

6. Information we collect

In providing our educational and performance management services to you, we collect certain non-personal and personal data about you. Our policy is to keep this information confidential and strictly safeguarded, and to use or disclose it only as needed to provide services to you, or as permitted or required by the Data Protection Legislation.

6.1 Information collected automatically

Whenever you visit our website, our web servers automatically collect non-personal information such as the domain name of your internet access provider, the IP address used to connect to the internet, average time spent on our website, pages viewed, information searched for, access times, usage statistics about your interactions with the Services (including content accessed and time spent), and other relevant statistics.

6.2 Information you provide us

If you contact us or subscribe to our services, we collect the following personal information:

• Username and password;
• Contact information;
• Details of your learning history, search queries, saved items and notification preferences, as well as your purchase history if you subscribe to our services;
• Information obtained during interactions with us — engaging with our sales team, contacting customer care, responding to surveys, taking part in promotional activities, registering for events or appointments, or applying for employment;
• Email preferences, including subscriptions to marketing communications;
• Instructor biometric information (e.g. facial images, voice recordings, or other biometric identifiers captured through video recordings);
• Identity information (e.g. photo ID, passport information, National ID card and nationality);
• Financial information where you make any payment for our services; and
• Any other information you provide to us.

7. Using your personal data

7.1 We primarily collect your personal data to provide the most efficient educational and performance management service, monitor and improve our website, and pursue our other legitimate interests. Your information is used and disclosed only for the following purposes:

• To help us verify your identity;
• To carry out our obligations under any contract entered into between you and us;
• To provide the products, services and information you request from us;
• To assist you with enquiries and improve our customer service;
• To carry out marketing and advertising, including communications tailored to your interests;
• To assist with marketing analysis, customer profiling, research, and statistical or testing information;
• To facilitate the technical functioning of our services, including troubleshooting, security, and preventing fraud and abuse;
• To communicate with you by any means (email, telephone, visit, text or multimedia message);
• For our billing and account purposes;
• To help prevent and detect fraud or loss;
• To update our records;
• To make recommendations and suggestions about our services, unless you've asked us not to;
• To send service or support messages — updates, security alerts, notifications and newsletters;
• To conduct investigations and risk assessments;
• As required or permitted by law, and for compliance with legal and regulatory obligations; and
• As we, in our sole discretion, otherwise determine necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our services.

7.2 Employees, agents, contractors or other parties working on behalf of Talstack collect your personal data only to the extent required for their job duties and in accordance with this policy. Excessive personal data must not be collected.

7.3 Employees, agents, contractors or other parties working on behalf of Talstack process your personal data only when the performance of their job duties requires it. Your personal data cannot be processed for unrelated reasons.

8. Data accuracy

Your personal data must be accurate and kept up to date. Talstack ensures that any data it collects or processes is accurate and not misleading in a way that could be harmful to you, makes reasonable efforts to keep your personal data updated, and makes timely efforts to correct or erase your personal data when inaccuracies are discovered.

9. Data retention

Talstack does not keep personal data for longer than necessary in light of the purpose for which it was originally collected. For your educational and/or performance management data, the purpose is to provide services that equip you with the technical skills needed for the careers of the future. Unless we receive a valid request to erase your educational data, it is retained permanently, or as otherwise permitted by applicable data protection legislation, so that your record of participation and progress in our educational program can be maintained. If the data were deleted, we would have no record of your performance and completion of our educational program.

10. Other information we collect

We may also collect information from you using cookies and other analytical tools, especially when you use our products and services. More detail is provided in the section on Cookies below.

11. Data confidentiality

Your information is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions. You have the right to request copies of any and all information we keep on you, where such requests comply with applicable laws. While we are responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes — but is not limited to — adopting and enforcing appropriate security measures such as not sharing passwords and other login details, adhering to physical security protocols on our premises, and dealing only with authorised officers of Talstack.

12. Disclosures

• We will not sell, publish or disclose your personal data to third parties other than to provide our services and as set out in this policy. We may share generic, aggregated demographic information not linked to any personally identifiable information with our business partners, trusted affiliates, professional advisers and advertisers for the purposes outlined above, and may share your information with third parties for limited purposes where you have given permission and in compliance with the Data Protection Legislation.
• We may request and provide information about you from and to third parties to provide our services.
• We will notify you as soon as we become aware of a harmful data breach that may result in a risk to your rights and freedoms.
• You have the right to request erasure of your data at any time.
• We will notify you if we are transferring your data.
• You may request at any time that we halt further dissemination of your data or cease to use it.
• If you submit content in a public forum, social media post, or similar feature on our website, that content is publicly visible.
• We may disclose personally identifiable information if required by law, or in the good-faith belief that doing so is necessary to comply with legal process served on us, or to act in urgent circumstances to protect the personal safety of users of our service or members of the public.
• To the extent practicable and legally permitted, we will attempt to advise you prior to any such disclosure, so that you may seek a protective order or other relief limiting it.

13. Transfer of personal data

13.1 Third-party processors

We may engage third parties to process your personal data. Their processing is governed by a written contract with Talstack, ensuring adequate protection and security measures in accordance with the terms of this policy and the Data Protection Regulation.

13.2 International transfers

Your information may be transferred to a foreign country or international organisation for the purpose of providing our services. We will ensure adequate data protection laws exist in the recipient country or organisation before any transfer, including assessing whether the country appears on the Nigeria Data Protection Commission (NDPC) whitelist of countries with adequate data protection laws, or other relevant authorities that may come into existence in jurisdictions where the company has offices.

Transfer of your personal data out of Nigeria is carried out in accordance with the NDPA. We will only transfer your personal data out of Nigeria where one of the following applies:

• Your explicit consent has been obtained;
• The transfer is necessary for the performance of a contract between you and Talstack;
• The transfer is necessary to conclude a contract between Talstack and a third party in your interest;
• The transfer is necessary for reasons of public interest;
• The transfer is for the establishment, exercise or defense of legal claims; or
• The transfer is necessary to protect your vital interests or those of other persons, where you are physically or legally incapable of giving consent.

Where you have been made to understand, through clear warnings, the specific data-protection principles likely to be violated by a transfer to a third country, this provision does not apply where you are answerable in a duly established legal action for a civil or criminal claim in another country. We take all necessary steps to ensure your personal data is transmitted safely and securely, and will provide details of the protection given to your information on request. Where none of the conditions above are met, Talstack will engage with the NDPC for approval of the transfer.

14. Your rights

Subject to certain limitations and exceptions, you are entitled to the following principal rights under the Data Protection Legislation:

• The right to be notified if we are transferring your personal information;
• The right to request erasure of your personal data at any time;
• The right to request that we rectify inaccurate personal information;
• The right to request that we halt further dissemination of your data or cease using it;
• The right to request copies of your personal information; and
• The right to opt out of marketing or advertising emails — via the unsubscribe link in any promotional email, by updating your preferences in your account, or by contacting builtwithlove@talstack.com.

If you opt out of marketing messages, you will still receive transactional and service-related emails necessary to your use of the Platform — such as order updates, membership notices, corrections to personal information, password resets, reminders you've requested, and updates to our terms and policies.

15. Website security

We are committed to ensuring your information is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures — such as secure sockets layer (SSL) — to safeguard the information we collect online, and we use encryption tools when accepting and transmitting sensitive visitor information. Other safeguards include firewalls, physical access controls to our data centres, and information access authorisation controls.

16. Training

We ensure that employees who collect, access and process your personal data receive adequate data privacy and protection training, developing the knowledge, skills and competence needed to manage our compliance framework under this policy and the Data Protection Legislation. On an annual basis, we develop a capacity-building plan for our employees on data privacy and protection.

17. Use of cookies

We use cookies to identify you as a user and make your experience easier, to customise our services, content and advertising, to help ensure your account security is not compromised, to mitigate risk and prevent fraud, and to promote trust and safety on our website. Cookies allow our servers to remember your account log-in information when you visit, track IP addresses and visit times, monitor web traffic, and prevent fraudulent activity. If your browser or browser add-on permits, you may disable cookies on our website; this may limit your ability to use the website.

18. The data we retain

We retain your information for as long as needed to provide you with our services, comply with our legal and statutory obligations, or verify your information with a financial institution. We are statutorily obligated to retain the data you provide to process transactions, ensure settlements, make refunds, identify fraud, and comply with applicable laws and regulatory guidelines.

19. Data breach management procedure

In the event of any accidental or unlawful destruction, processing, loss, alteration, or unauthorised disclosure of or access to your personal data, we shall:

• Notify you within 24 hours of the occurrence of the data breach;
• Properly investigate the breach and take the necessary steps to mitigate it;
• Identify remediation requirements and track the resolution of the breach; and
• Notify the Information Commissioner's Office or any other regulatory authority, where necessary.

20. Links to third-party websites

Our website may contain links to third-party websites or services that are not owned or controlled by us. We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party websites or services, and we are not responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with your use of or reliance on such content, goods or services. We strongly advise you to read the terms and privacy policies of any third-party websites or services you visit.

21. Limitation of liability

We exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, we will not be liable for unauthorised disclosure of personal data that occurs through no fault of ours.

22. Changes to this privacy policy

Changes may be made to this Privacy Policy from time to time. Whenever such changes are made, we will notify you, and the changes will take effect immediately after you have been notified.

23. Contact us

If you would like more information, or have any comments or questions on our Privacy Policy, please contact us.