Aemo Consult Limited Privacy Notice
1. Introduction
Please read this privacy notice (“Privacy Notice”) to understand how Aemo Consult Limited (“Aemo Consult”, “We” or “Us”) use and/or share your information (“Personal Data”) as our customer when you use our website (the “Platform”).
You need to read the privacy notices of the third-party platforms or partners that We work with to provide our services to you to understand their respective privacy practices before accessing their websites.
2. About Us
Aemo Consult is a digital marketplace connecting individuals and organisations seeking tutoring services with qualified tutors. The Platform facilitates direct engagements between:
2.1. Tutors: teachers, educators, or professionals offering tutoring services; and
2.2. Clients: including individuals (parents and students seeking tutoring services) and organisations (schools, firms, and other entities requiring educational support).
Aemo Consult is not a school and does not provide tutoring services. It solely acts as an intermediary, providing a space for users to connect and arrange their service agreements. All tutor recommendations are subject to the Client’s approval.
3. Eligibility
3.1. Minors: The Platform is intended solely for users aged 18 (eighteen) years old and above. By accessing or using the Platform, you represent and confirm that you are at least 18 (eighteen) years old. We do not knowingly engage with or provide services to individuals under 18 (eighteen) years without parental or legal guardian supervision. Any minor using the Platform must access the services through a parent or legal guardian, who shall be fully responsible for overseeing the minor’s use of the service. We reserve the right to automatically terminate your use of our Platform if you violate this section of the Terms.
Important Note: Parents/guardians must supervise all tutoring sessions at all times.
4. Your Rights
You can exercise the following rights with respect to your Personal Data with Aemo Consult:
4.1. request and access your Personal Data collected and stored by Aemo Consult;
4.2. withdraw consent at any time;
4.3. object to automated decision-making;
4.4. request rectification and modification of Personal Data kept by Aemo Consult;
4.5. request for the deletion of your Personal Data;
4.6. be informed of and entitled to provide consent prior to the processing of Personal Data for purposes other than that for which the Personal Data was collected;
4.7. request that Aemo Consult restrict the processing of your Personal Data; and
4.8. request for information regarding any specific processing of your Personal Data.
You may exercise any of these rights by sending an email to dpo@aemotutors.com, where your requests will be treated promptly. You may also reach out to the regulator by sending an email to info@ndpc.gov.ng
5. The Information We Collect and Lawful Basis for Processing Personal Data
5.1. We require your Personal Data as a prerequisite for providing our services to you. Below are the information that We collect when you use our Platform:
Category | Who We Collect Information From | Information We Collect | How We Use It | Lawful Basis for Processing | Who We Share the Data with | Retention Period |
Clients | Parents, students, and organisations seeking tutoring services.
| Full legal name, valid email address, home address, phone number, and Government-issued Identity Card (e.g., National ID, passport, driver’s licence). | Know-Your-Customer (KYC) verification, background checks. | – Legal obligation: To comply with regulatory requirements mandating the collection and processing of certain Personal Data. – Legitimate interests: (ours and those of others) such as to protect you, us, or others from threats (such as security threats or fraud); to enable or administer our business, such as for quality control, compliance, consolidated reporting and customer service; to manage corporate transactions, such as mergers or acquisitions; and to understand and improve our business or customer relationships generally. – Contractual obligation: To fulfill a contract We have with you, or because We have asked you to take specific steps before entering that contract. – Compliance checks: to ensure ongoing compliance with legal and regulatory obligations | Third parties for background checks, identity verification, and other necessary compliance processes. | 7 years |
Tutors | Individuals offering tutoring services. | Full legal name, valid email address, home address, phone number, country of residence, and location from which you are accessing our service, disclosure of criminal records, relevant professional qualifications, copy of Government-issued Identity Card (e.g., National Identity Number ), and passport photograph. | KYC verification, background checks, processing applications, and maintaining contractual relationships. | – Clients; – Organisations (schools, firms, and other entities requiring educational support); – Third parties for background checks, identity verification, and other necessary compliance processes. | ||
Student | Students receiving tutoring services. | Full name, date of birth, gender, class, school category (day/boarding), name of current school, school ID, or other relevant identification. | KYC verification, connecting with tutors, and personalised experience. | Contractual obligation. | Clients and Tutors for identity verification. | 3years |
Location Information | Clients/Tutors | Country of residence and the location from which you are accessing our service. | Connecting with local Clients and Tutors, personalised experience, and troubleshooting. | Legitimate interests. | NIL | 3 years |
Employment Data | Tutors and Employees. | Previous employment information, professional qualifications, experience, and tax information (for employees), guarantors, and contact information. | Processing tutor applications, maintaining employment relationships, and conducting background checks | Legal obligation and compliance checks. | Third party for KYC and background checks. | 7 years |
Complaint Resolution Data | Clients/Tutor | Information related to dispute resolution and complaints. | Addressing complaints, processing feedback, and enhancing service delivery. | Legitimate interests
| NIL | 3 years |
Website/Technical Data | Clients/Tutor | Data collected for the Platform usage analysis, troubleshooting, and service improvement. | Enhancing user experiences, enabling targeted displays, and personalising Platform interactions. | Legitimate interests. | NIL | Not specified. |
5.2. Please note that, where there is a valid order from a court of competent jurisdiction or in support of a valid investigation by law enforcement, We may share your Personal Data with a regulator. We may also share aggregated or anonymised Personal Data, which cannot reasonably be used to identify you, with our partners, vendors, or independent contractors. For example, We may share transaction zip codes with third parties to improve our accuracy in geo-locating transactions and the clarity of the transaction description.
5.3. Withdrawing Consent
You can withdraw your consent at any time. However, withdrawing consent does not affect any data processing that was carried out lawfully prior to the withdrawal.
5.4. If you no longer wish to receive targeted displays, features, or any of our services, please send an email to aemotutors@gmail.com.
6. Sharing of your Personal Data
We may share the minimum required Personal Data between Clients and Tutors strictly to facilitate service delivery. Additionally, We may transfer your Personal Data to third-party service providers for background checks, identity verification, and other necessary compliance processes. However, We strictly adhere to regulatory guidelines relating to such transfers, including:
6.1. Verifying that the recipient maintains adequate protection and sound data practices;
6.2. Relying on your consent or another lawful basis; or
6.3. Compliance with a valid legal obligation, such as a court order.
7. Transfer of your Personal Data
Our Platform is primarily hosted in Nigeria and governed by Nigerian Laws, however, We may transfer your Personal Data outside Nigeria, including international service providers such as Google Analytics (for technical and analytics support). Where such transfers occur, We ensure they are compliant with relevant data protection laws and safeguard your rights. This includes:
7.1. Ensuring an adequate level of protection and proper data handling by the recipient;
7.2. Relying on your consent where other safeguards are unavailable. By using this platform from outside Nigeria or by submitting your data, you consent to such transfers; and
7.3. Transfers required in the public interest or under applicable law.
8. Online activities tracking
You accept that Aemo Consult shall have the right to monitor your activities on our Platform and, if required, will disclose your Personal Data to local enforcement or investigative agencies or any competent regulatory or governmental agencies to assist in the prevention, detection or prosecution of fraud or criminal activities.
9. Aemo Consult Employee Obligation
Aemo Consult employees who handle Personal Data are obligated to treat it confidentially and must not disclose it to third parties. Aemo Consult employees are also responsible for the internal security of such information. Employees who violate Aemo Consult’s Privacy Notice will be subject to the company’s disciplinary procedures.
If you receive any electronic mail (email) or a request for your financial account details from anyone claiming to work for Us or acting on our behalf, please forward the email or report the incident to info@aemotutors.com.
10. Submitting Information Through Aemo Consult
When you submit information to Aemo Consult through our Platform, you may have the right to access and correct that information. Aemo Consult has systems in place to help you update and correct your Personal Data to ensure it is accurate, current, and compliant with the Nigeria Data Protection Act, 2023 (“NDPA”). Please notify Us at aemotutors@gmail.com if there are any changes to your Personal Data to keep your information current, complete, and accurate. If We do not hear from you, We will assume that your records are accurate and up-to-date.
11. Privacy Notice Updates
Aemo Consult may update this Privacy Notice at any time by posting a revised version on our website, and you will be deemed to agree to the changes if you continue using our Platform. If new processing requirements arise that are not covered by the existing lawful basis (such as your consent), We will request your consent or rely on another lawful basis in accordance with applicable laws. If you do not accept any changes, you are required to close your Aemo Consult account. Please note that closing the account does not absolve you of any liabilities incurred before the closure.
12. Security and Storage of Data
Aemo Consult is committed to safeguarding your Personal Data using top-tier security measures. We employ physical, technical, and administrative controls to prevent loss, misuse, unauthorised access, disclosure, and alteration of your data. Your data is securely stored in our database and is encrypted to enhance its protection.
Although We make good faith efforts to store information in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security, and We do not guarantee that there will be no unintended disclosures of your information. If We become aware that your information has been disclosed in a manner not in accordance with this Privacy Notice, We will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent We know that information) as soon as reasonably possible and as permitted by law.
13. Phishing
Phishing is the name given to attempts to steal personal and financial account details from a website user. “Phishers” use fake or “spoof” emails to lead users to counterfeit websites where the user is tricked into entering their personal information, such as credit card numbers and account details.
If you receive such an e-mail or are asked for your financial account details by anyone claiming to work for us, please forward the e-mail or report the incident by e-mail at aemotutors@gmail.com.
14. Contact Information
For any questions about this Privacy Notice or Aemo Consult’s information services, you can contact Us via our customer helplines or by email at aemotutors@gmail.com.