CLARYLIFE MENTORSHIP ACADEMY
Privacy Policy
Effective: April 2026 · acad.clarylifeglobal.com

Administered by: Clarylife Global, Port Harcourt, Nigeria.
Contact: clarylife.ma@gmail.com

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1. WHO WE ARE
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The Clarylife Mentorship Academy (referred to in this Policy as “the Academy”, “we”, “us”, or “our”) is an educational initiative operated by Clarylife Global, a systems automation agency registered and operating in Port Harcourt, Nigeria.

Our website is located at acad.clarylifeglobal.com. This Privacy Policy applies to all pages, services, and interactions associated with that website and with the Academy’s programme operations.

When you visit our website, submit an application, make a payment, or participate in the Programme in any capacity, you are entrusting us with information about yourself. We take that responsibility seriously. This Policy explains clearly what data we collect, why we collect it, how we use it, how long we keep it, and what your rights are in relation to it.

If you have any questions about this Policy or about how your data is handled, contact us at claryli2. THE LEGAL FRAMEWORK GOVERNING THIS POLICY
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This Policy is written in compliance with the Nigeria Data Protection Regulation (NDPR) 2019, issued by the National Information Technology Development Agency (NITDA), and the Nigeria Data Protection Act (NDPA) 2023.

Where visitors or applicants access the Academy from outside Nigeria, we acknowledge applicable international data protection principles including those embodied in the General Data Protection Regulation (GDPR) of the European Union, and we apply equivalent standards of care to all personal data regardless of the visitor’s location.

Your use of this website and your participation in the Programme constitute acceptance of this Policy.

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3. WHAT DATA WE COLLECT AND WHY
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We collect only the data that is necessary for the Academy to function effectively and to serve you well. Below is a full account of every category of data we collect and the purpose for which each is collected.

3A. DATA YOU PROVIDE DIRECTLY

Application Data
When you submit an application to the Programme, we collect: your full name, email address, phone number, and your responses to the application questions. This data is used solely to assess your suitability for admission and to communicate with you about your application.

Enrolment and Payment Data
When you proceed to enrolment, we collect: the personal information required to process your payment through our payment gateway (Paystack), and to create your account on the Student’s Portal. Payment card details are not stored by us at any point — they are processed and secured entirely by Paystack, in accordance with Paystack’s own privacy and security standards. We receive only a confirmation of payment and a transaction reference.

Student’s Portal Data
Once enrolled, your activity on the Student’s Portal — including assignment submissions, grades, course progress, and certificate records — is stored within the LMS platform that powers acad.clarylifeglobal.com. This data is used exclusively to manage your progress through the Programme and to issue your certificate upon successful completion.

Email and Direct Communications
When you contact us via email or any direct channel, we retain the content of those communications to the extent necessary to respond to your enquiry, resolve any dispute, or maintain a record of Programme-related decisions.

3B. DATA COLLECTED AUTOMATICALLY

Website Usage Data
When you visit acad.clarylifeglobal.com, our website automatically collects certain technical information, including: your IP address, browser type and version, operating system, referring URL, pages visited, time and date of visit, and the duration of your session. This data is collected to monitor website performance, identify technical issues, and understand how visitors navigate our site. It is not used to personally identify visitors unless a specific legal or security concern requires us to do so.

Cookies and Tracking Technologies
We use cookies and similar technologies on our website. A cookie is a small text file placed on your device by a website you visit. Cookies allow the website to recognise your device on return visits and to function correctly. A full description of the cookies we use is provided in Section 6 of this Policy.

3C. DATA COLLECTED THROUGH THIRD-PARTY PLATFORMS

Discord
Enrolled students participate in the Programme’s official community server on Discord. Discord is an independent third-party platform with its own privacy policy. We do not control the data Discord collects about you through their platform. We do, however, moderate the community server and retain records of conduct-related communications where those records are necessary for Programme administration or enforcement of the Code of Conduct.

Social Media Participation
As part of the Cohort 1 experience, students are expected to post publicly on LinkedIn or Twitter/X using the designated CMA hashtag. These posts are made on your own accounts, on platforms governed by their own respective privacy policies. We do not collect or store personal data from your social media profiles. We may, however, engage with, share, or reference public posts made using the CMA hashtag for community visibility purposes. If you do not wish your post to be shared by the Academy, contact us at clarylife.ma@gmail.com.

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4. THE LEGAL BASIS ON WHICH WE PROCESS YOUR DATA
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We process your personal data on the following legal grounds, consistent with the NDPR and NDPA:

Contractual Necessity — The majority of the data we collect is required to fulfil our obligations to you as a student or applicant. Processing application data, payment information, and Student’s Portal records falls under this basis.

Legitimate Interests — Website usage analytics and technical data are processed on the basis of our legitimate interest in operating a functional and secure website. We ensure that this interest does not override your rights or interests.

Consent — Where we collect data that is not strictly necessary for programme delivery — such as featuring your work or journey in marketing communications — we obtain your explicit consent beforehand, and you retain the right to withdraw that consent at any time.

Legal Obligation — We may process and retain certain data where required to do so by applicable Nigerian law or regulatory authority.

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5. HOW WE SHARE YOUR DATA
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We do not sell, rent, trade, or otherwise transfer your personal data to any third party for commercial purposes. Full stop.

We share data only in the following limited circumstances:

Service Providers — We work with third-party service providers whose tools are integral to the operation of the Programme. These include Paystack (payment processing) and the platforms that power our website (WordPress), Student’s Portal (LearnDash), and email communications. These providers are engaged solely to process data on our behalf and are not permitted to use your data for any other purpose.

Legal Requirements — We may disclose your personal data if required to do so by a Nigerian court order, regulatory authority, or other applicable legal process.

Protection of Rights — We may disclose data where we have a good-faith belief that doing so is necessary to protect the rights, property, or safety of Clarylife Global, its students, staff, or the public.

In all cases, we limit the data shared to the minimum necessary for the stated purpose.

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6. COOKIES
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This section explains the cookies used on acad.clarylifeglobal.com, what they do, and how you can control them.

WHAT ARE COOKIES?

Cookies are small text files stored on your device when you visit a website. They allow the website to remember information about your visit — such as your login status or preferences — so that the site functions correctly and your experience is consistent.

THE COOKIES WE USE

Strictly Necessary Cookies
These cookies are essential for the website to function. They cannot be disabled without breaking core site functionality. They include cookies that manage your login session on the Student’s Portal, maintain your shopping cart during the enrolment and payment process, and preserve your security tokens across pages. No personal information is transmitted by these cookies beyond what is technically required.

Functional Cookies
These cookies remember your preferences and improve your experience on the site. They include cookies that retain your language preferences, your form progress, and similar settings. These cookies do not track your activity across other websites.

Performance and Analytics Cookies
These cookies collect anonymous information about how visitors use the website — which pages are visited most, where visitors come from, and how long they spend on each page. This data is used in aggregate form only and cannot be used to identify you personally. We may use tools such as Google Analytics or equivalent for this purpose.

Payment and Transaction Cookies
During the payment process, cookies from our payment gateway (Paystack) are activated to manage the transaction session securely. These cookies are governed by Paystack’s own cookie and privacy policies and are not stored beyond the duration of the transaction session.

YOUR COOKIE CHOICES

When you first visit our website, you will be presented with a cookie consent notice. You may accept all cookies, accept only strictly necessary cookies, or customise your preferences. You may change your cookie preferences at any time by clearing your browser’s cookies and revisiting the site.

You may also control cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling strictly necessary cookies may prevent parts of the website — including the Student’s Portal and payment pages — from functioning correctly.

For more information on managing cookies in your browser, visit the support documentation for your browser provider.

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7. DATA RETENTION
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We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law.

Application Data — Retained for a period of six months following the close of the relevant cohort’s application window, after which it is securely deleted. If your application results in admission, your data is retained as part of your student record.

Student Records — Including assignment submissions, grades, capstone project files, and certificate records — are retained for a minimum of three years following the conclusion of the Programme. This retention period supports the integrity of the certification credential and enables the Academy to verify records on request.

Payment Records — Transaction references and payment confirmation records are retained for a minimum of five years in compliance with Nigerian financial record-keeping obligations.

Communication Records — Email and Programme-related communications are retained for a period of two years following the conclusion of the Programme, unless a longer retention period is required by an ongoing dispute or legal matter.

Website Analytics Data — Retained in aggregated, anonymised form for up to two years.

When retention periods expire, data is securely deleted or anonymised so that it can no longer be attributed to you.

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8. DATA SECURITY
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We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, disclosure, alteration, or destruction.

These measures include: secure HTTPS connections across all pages of the website; access controls that limit who within the Academy can view personal data; use of reputable, security-certified third-party platforms for payment processing and LMS operations; and regular review of our data handling practices.

No method of transmission over the internet is completely secure. While we take all reasonable precautions, we cannot guarantee absolute security. In the event of a data breach that is likely to result in risk to your rights or freedoms, we will notify you and the relevant regulatory authority in accordance with our obligations under the NDPA.

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9. YOUR RIGHTS
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Under the Nigeria Data Protection Regulation and the Nigeria Data Protection Act, you have the following rights in relation to your personal data:

Right of Access — You have the right to request a copy of the personal data we hold about you.

Right to Rectification — You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.

Right to Erasure — You have the right to request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to any legal retention obligations.

Right to Restriction — You have the right to request that we restrict the processing of your data in certain circumstances — for example, while the accuracy of the data is in dispute.

Right to Object — You have the right to object to the processing of your data on the grounds of legitimate interests, where you believe your interests or rights override ours.

Right to Withdraw Consent — Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

Right to Complain — If you are dissatisfied with how we have handled your personal data, you have the right to lodge a complaint with the National Information Technology Development Agency (NITDA), the data protection supervisory authority in Nigeria.

To exercise any of the above rights, contact us in writing at clarylife.ma@gmail.com. We will respond to all legitimate requests within 30 days. Where a request is complex or numerous, we may extend this period by a further 30 days and will notify you accordingly.

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10. CHILDREN AND MINORS
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The Clarylife Mentorship Academy is designed for adults. We do not knowingly collect personal data from individuals under the age of 18. If you are under 18, you may not apply to or enrol in the Programme without the documented consent of a parent or legal guardian.

If we become aware that we have inadvertently collected data from a person under the age of 18 without appropriate consent, we will delete that data promptly. If you have reason to believe such a case has occurred, contact us at clarylife.ma@gmail.com.

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11. LINKS TO THIRD-PARTY WEBSITES AND PLATFORMS
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Our website and Programme communications may contain links to external websites and platforms — including Discord, LinkedIn, Twitter/X, Paystack, and others. Once you leave acad.clarylifeglobal.com, this Privacy Policy no longer applies.

We are not responsible for the privacy practices or content of any third-party platform. We encourage you to read the privacy policy of every external platform you interact with in connection with the Programme.

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12. CHANGES TO THIS POLICY
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We may update this Privacy Policy from time to time to reflect changes in our operations, technology, legal obligations, or the structure of the Programme. When we do, we will update the effective date at the top of this document and, where the changes are material, notify enrolled students directly via email.

We encourage you to review this Policy periodically. Your continued use of the website or participation in the Programme following the publication of any changes constitutes your acceptance of the updated Policy.

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13. CONTACT AND DATA CONTROLLER INFORMATION
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The data controller responsible for your personal data is:

Clarylife Global
Operating the Clarylife Mentorship Academy
Port Harcourt, Rivers State, Nigeria
Email: clarylife.ma@gmail.com
Website: acad.clarylifeglobal.com

For all data-related enquiries, access requests, or complaints, write to us at the email address above. We are committed to handling all such communications promptly and transparently.

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Clarylife Mentorship Academy · Cohort 1 · April 2026
We build systems. We grow people.
acad.clarylifeglobal.com
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