Legal

Privacy Policy

Effective 24 October 2026 · Version privacy-v2-2026-10-24

In short

We collect as little as we can: your name and WhatsApp number, and your child’s first name, age and learning progress. Never a child’s surname, photo, school or location.
We use your family’s data only to teach your child, keep them safe, run your account and send invoices. We never sell it, never show adverts, and never use it for marketing to your child.
A parent or legal guardian consents before anything about a child is stored, and can withdraw that consent, download the family’s data, or ask for it to be deleted at any time.
Some of our providers process data outside Nigeria, under safeguards described below.

This summary helps you read the full text below. The full text is what applies.

1. Who is responsible for your data

Phil’s Cohort is the data controller for personal data processed through the Service. We follow the Nigeria Data Protection Act 2023 and the regulations and directives made under it, and, where they apply to you, other data protection laws.

To ask about your data or exercise your rights, contact us through the family app (Help, then Talk to a person), or on WhatsApp at +2349042510558. Please put “Data request” in your message.

2. What we collect

About	What	Why
You (the guardian)	Your name, WhatsApp number and password (stored only in scrambled form). Messages you send us. Your consent and acceptance records.	To create and secure your account, talk with you, and prove what you agreed to.
Billing	Your family’s plan, invoices, payments you tell us about and their references, reminders and any paused access.	To bill you, keep accounts, and pause or restore access.
Your child	First name, age at registration (and year of birth, if a mentor records it), sign-in username, and the account status a mentor sets.	To give them a place and a sign-in.
Your child’s learning	Lessons started and mastered, answers, quiz marks, messages with the AI tutor, commands typed in the lab, mentor notes, and alerts when they are stuck.	To teach, mark work, adapt lessons, and let the mentor help.
Chats with the assistant and our team	What you type to the help assistant on the website or in the family app, its replies, and messages with our team. On the website you are not named unless you choose to be: the chat is linked only to a random key your browser keeps.	To answer you, to let our team see how people are being helped and join in when it helps, and to improve the help centre.
Enquiries from the website	If you ask the website assistant for a person: your name, your WhatsApp number and/or email, your child’s age if you give it, your question, and your agreement to be contacted.	To reply to you and follow up on your enquiry. Never for anything else, and never shared for marketing.
Technical	The browser details at the moment consent is given, and internet addresses, used briefly to limit abuse. Addresses are scrambled before anything is stored.	To keep the Service secure and prove consent.

We do not collect a child’s surname, photo, school, address, location, voice or email. The tutor reads lessons aloud, but nothing your child says is recorded: children type, they are not listened to.

3. Our lawful reasons

Consent: the parent or guardian’s consent, given at registration, for collecting and using a child’s data, and for optional preference cookies. You can withdraw consent at any time; this does not affect what was done before.
Contract: to provide the Service you asked for, run your account and send invoices.
Legal obligation: to keep financial records and respond to lawful requests.
Legitimate interests: to keep the Service secure, prevent misuse, protect children, and improve the help centre, in ways that do not override your or your child’s rights.
Vital interests: in the rare case that we must act to protect a child from serious harm.

4. Children

All our students are children. Under the Nigeria Data Protection Act a child is anyone under 18, so we process a child’s data only with the consent of their parent or legal guardian, and we ask the guardian to confirm their identity and age at registration.

Children cannot contact other students through the Service. Their progress is visible only to their own family, their mentor and the staff who support them. Demos and posts never show real student names, faces or sign-in details.

5. How we use AI

An AI tutor teaches lessons, explains ideas, marks short answers and writes progress notes for the mentor. An AI help assistant answers questions from the help centre, and our team can see these chats and may join one to help. To do this, the text of a lesson conversation or a help question is sent to our AI provider, which processes it to produce a reply on our behalf.

We send only what is needed for the reply. We never send a guardian’s contact details to the AI. No decision with legal or similarly significant effects is made about you or your child by AI alone: a human mentor oversees each child, and you can ask for any mark or decision to be reviewed by a person.

7. Data processed outside Nigeria

Some of our providers store or process data in other countries, including the United Kingdom, the European Union and the United States. Where we transfer personal data outside Nigeria, we do so as the Nigeria Data Protection Act allows: to countries or under contracts that give it adequate protection, or with your consent, which you give by registering. You may ask us for more detail about these safeguards.

8. How long we keep it

Account and learning data: while the account is open. When you close it or ask us to delete it, we erase it within 30 days, apart from what is listed below.
Invoices and payment records: kept for six years, because tax and company law require it. When we erase a family, we remove the child’s name and the family’s contact details from these records.
Consent and acceptance records: kept for as long as we may need to show that consent was given, then deleted with the account.
Chats with the assistant, and website chats: deleted 30 days after the last message. Conversations with our team in the family app: kept for a year after they are resolved, as support records.
Enquiries from the website: kept for a year from your last contact with us, then deleted. Ask us and we delete yours sooner.
Unanswered help questions and saved help answers: kept without anything that identifies who asked.
Backups: overwritten in the normal backup cycle after erasure.

9. Keeping it secure

Data is encrypted in transit. Passwords are stored only in scrambled form. Staff see only what their role needs: mentors see their students’ learning, support staff see family conversations, and only administrators see billing. Sensitive staff actions, such as password resets, exports and erasures, are logged.

If a breach puts your rights at risk, we will tell the Nigeria Data Protection Commission within 72 hours of becoming aware of it, and tell you without undue delay where the risk is high.

10. Your rights

You have the right, for yourself and for your child:

to know what we hold and get a copy (in the family app: Account, then Download our data);
to have it corrected if it is wrong;
to have it deleted (Account, then Ask us to delete our data), and to withdraw consent;
to restrict or object to how we use it;
to receive it in a portable format;
to ask for a person to review any decision made with AI;
to complain to the Nigeria Data Protection Commission.

We respond within 30 days. We may ask you to confirm your identity first, to protect your family’s data. Contact us through the family app (Help, then Talk to a person), or on WhatsApp at +2349042510558.

11. Cookies

We use cookies and similar storage only to sign you in, keep the Service working and, if you allow it, remember your preferences. We use no advertising or tracking cookies. The Cookie Policy lists each one and lets you change your choice.

12. Changes to this policy

We will show the date and version at the top. For changes that matter, we will ask you to accept the new version in the family app.