Privacy Policy
Learnep Technologies LTD Last updated: 7th July, 2026
1. Introduction
Learnep Technologies LTD (“Learnep,” “we,” “us,” or “our”) provides a cloud-based Learning Management System (LMS) designed to help organizations deliver, manage, track, and improve learning experiences. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have over it.
This policy applies to visitors to our website (learnep.com), administrators and employers who register an organization account, and learners/employees who use Learnep through their organization’s account.
We process personal data in accordance with the Nigeria Data Protection Act (NDPA) 2023 and its General Application and Implementation Directive (GAID) 2025, issued by the Nigeria Data Protection Commission (NDPC).
2. Who We Are
Data Controller: Learnep Technologies LTD
Registered address: 115 Udo Umana Street, Uyo, Akwa Ibom, Nigeria
Contact for privacy matters: privacy@learnep.com
3. Data We Collect
We collect different categories of personal data depending on how you interact with Learnep:
a) Website visitors
- Contact form submissions (name, email address, message content, organization name if provided)
- Newsletter sign-ups (name, email address)
- Website usage and analytics data (see Section 7)
b) Employer / Administrator accounts
- Name, work email address, job title, organization name
- Organization details (company size, industry, billing/contact information)
- Account credentials and account activity logs
c) Learner / Employee data (once an organization is onboarded)
- Name and work email address
- Course enrollment and progress data
- Quiz and assessment scores
- Certification and completion records
- Login and platform usage activity
d) Organization data
- Company/organization profile information
- Training program structure and configuration data uploaded by administrators
e) Data from optional integrations (only where an organization administrator chooses to enable them — see Section 8)
We do not knowingly collect special categories of sensitive personal data (health, biometric, religious, or similar data) unless an organization specifically configures training content that requires it, in which case that organization — as the relevant data controller for its own employees — is responsible for the lawful basis for that collection.
4. How We Use Your Data
We use personal data to:
- Provide, operate, and maintain the Learnep platform
- Create and manage user and organization accounts
- Track learner progress, completions, and certifications on behalf of the organization that employs the learner
- Respond to inquiries submitted through our contact form
- Send newsletters and product updates to subscribers who have opted in
- Improve platform performance, usability, and security
- Meet legal, regulatory, and compliance obligations
- Communicate important service updates to administrators
- Enable optional integrations an organization chooses to activate (Section 8)
We do not sell personal data to third parties.
5. Legal Basis for Processing
Under the NDPA, we rely on one or more of the following lawful bases depending on the type of processing:
- Consent — for newsletter sign-ups and optional cookies/tracking
- Contract — to provide the LMS service to organizations that have signed up for an account
- Legal obligation — to comply with applicable Nigerian law and regulatory requirements
- Legitimate interest — for basic website analytics and platform security, balanced against your rights
Where an organization uploads learner/employee data to Learnep, that organization is generally the data controller for its employees’ data, and Learnep acts as a data processor on that organization’s behalf and instructions.
6. Cookies and Tracking
Our website uses Google Analytics to understand how visitors use our site and improve our content and platform. In line with NDPA/GAID requirements, we only set non-essential cookies (such as analytics cookies) after obtaining your opt-in consent through our cookie banner. You can manage or withdraw cookie consent at any time through your browser settings or our cookie preference tool.
7. Third-Party Service Providers
We work with the following trusted third-party service providers to operate Learnep:
| Provider | Purpose |
|---|---|
| Google Analytics | Website traffic and usage analytics |
| Zoho | Business email and communication |
| Mailchimp | Newsletter and email marketing delivery |
| Paystack | Payment processing (Nigeria/Africa) |
| Stripe | Payment processing — planned for future rollout |
| DigitalOcean | Cloud hosting and data storage infrastructure |
These providers only process personal data on our instructions, for the specific purpose of delivering their service to us, and are contractually required to protect your data in line with applicable law. We will update this table as our vendor relationships change.
8. Integrations You May Enable
Learnep supports optional integrations that an organization’s administrator can choose to activate. These are not automatically enabled — an organization controls whether and how they are used:
- Learning content standards: SCORM, xAPI (Experience API), cmi5, and TinCan — used to import and track third-party course content and its completion data within Learnep
- Video conferencing: Google Meet, Zoom, BigBlueButton, and Microsoft Teams — used to host live/virtual training sessions; may share meeting attendance and session data between Learnep and the connected platform
- HR and CRM systems: BambooHR, HubSpot, and other CRMs — used to sync employee/contact records between Learnep and an organization’s existing systems
- Productivity tools: Google Workspace, Microsoft Office, and Slack — used for single sign-on, file access, or notifications, depending on configuration
When an organization enables an integration, personal data may flow between Learnep and that third-party service in line with the organization’s configuration and that provider’s own privacy policy. Learnep is not responsible for the privacy practices of third-party platforms an organization independently chooses to connect, and we encourage organization administrators to review those providers’ privacy terms before enabling an integration.
9. Data Sharing and Disclosure
We may share personal data with:
- Third-party service providers listed in Section 7, strictly to deliver their service to us
- Third-party platforms an organization has chosen to connect via an integration (Section 8), only as configured by that organization
- The organization that a learner is enrolled under (for learner progress and completion data)
- Regulatory or law enforcement authorities, where required by law
- A successor entity, in the event of a merger, acquisition, or sale of business assets, subject to equivalent privacy protections
We do not share personal data with third parties for their own independent marketing purposes.
10. International Data Transfers
Learnep’s data is hosted with DigitalOcean [NYC]. Where personal data is transferred outside Nigeria, we ensure this is done in accordance with NDPA requirements, using recognized safeguards such as contractual data protection clauses with the receiving party, and only where the destination offers an adequate level of data protection.
11. Data Retention
We retain personal data only for as long as necessary for the purposes described in this policy.
| Data type | Proposed retention |
|---|---|
| Contact form submissions | 12 months from submission, unless a business relationship begins |
| Newsletter subscriber data | Until you unsubscribe, or 24 months of inactivity |
| Organization/admin account data | Duration of active subscription, plus 24 months after termination for legal, audit, and dispute-resolution purposes |
| Learner progress/certification data | Duration of the organization’s active subscription, plus any retention period specifically requested by that organization for certification/compliance records |
| Account activity/security logs | 12 months |
After the applicable retention period, data is securely deleted or anonymized unless a longer period is required by law.
12. Data Security
We implement reasonable technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction, including access controls, encryption in transit, and regular review of our security practices. No system is completely secure, and we continuously work to strengthen our safeguards.
13. Your Rights as a Data Subject
Under the NDPA, you have the right to:
- Access the personal data we hold about you
- Correct inaccurate or incomplete data
- Request deletion of your data, subject to legal retention requirements
- Restrict or object to certain processing
- Data portability, where technically feasible
- Withdraw consent at any time, where processing is based on consent
- Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your rights have been violated
To exercise any of these rights, contact us at privacy@learnep.com. We will respond within a reasonable timeframe in line with NDPA requirements.
If you are an employee/learner and your data was uploaded by your employer/organization, some requests (such as deletion) may need to be directed to or coordinated with your organization’s administrator, as they are the data controller for that data.
14. Children’s Privacy
Learnep is intended for use by working professionals and organizations. We do not knowingly collect personal data from children under the age of 18 through our public website. If Learnep is used in an educational context involving minors, the responsible organization is accountable for obtaining appropriate consent in line with applicable law.
15. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the updated version on this page with a revised “Last updated” date, and where changes are significant, we will provide additional notice.
16. Contact Us
If you have questions about this Privacy Policy or how we handle your data, contact us at:
Learnep Technologies LTD 115 Udo Umana Street, Uyo, Akwa Ibom, Nigeria Email: privacy@learnep.com