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Privacy Policy

Privacy Policy

Effective Date: August 8, 2026

Last Updated: August 8, 2026

This Privacy Policy (“Policy”) describes how Boki Youth Development Foundation (the “Foundation”), a nonprofit corporation incorporated in the State of Minnesota that has applied for tax-exempt recognition under Section 501(c)(3) of the U.S. Internal Revenue Code (IRS determination pending), and Boki Technology Hub (the “Hub”), a for-profit enterprise registered with the Nigerian Corporate Affairs Commission (CAC) (together, “Boki Youth Development Foundation and Boki Technology Hub,” “we,” “us,” or “our”), collect, use, store, share, and protect your personal information when you access or use our platforms, websites, learning management systems, computer-based testing and assessment tools, mobile applications, solar-powered digital learning centers, or any related programs and services (collectively, the “Service”). By enrolling in, visiting, or otherwise using the Service, you consent to the practices described in this Policy.

The Foundation and the Hub operate as a strategic “One Mission, Two Paths” pairing based in Boki Local Government Area (LGA), Cross River State, Nigeria. The Foundation provides fully subsidized, charitable digital education, technology-enabled assessment, and IT vocational training to underserved youth, women, and marginalized populations. The Hub provides market-rate, commercial digital and technology services to businesses and individual clients. Both entities are powered entirely by renewable solar energy and may share certain infrastructure, staff, and systems as described in Section 14 below.

  1. Information We Collect

We collect the following categories of information:

  1. a) Information You Provide Directly
  • Account and Enrollment Information. When you register for a Foundation training program, Hub service, or online account, we collect your full name, date of birth, gender, phone number, email address, physical/village address, password, and any information you choose to provide during registration or enrollment.
  • Beneficiary and Applicant Information. For Foundation programs, we may collect household income level, educational background, employment status, disability status (where voluntarily disclosed to support accommodations), and guardian or next-of-kin contact details for eligibility screening and program safety.
  • Profile Information. Profile photos, bios, usernames, trainer or mentor assignments, and other details you add to your learner or client profile.
  • Assessment and Certification Data. Test registrations, exam responses, scores, proctoring records, and certificates generated through our technology-enabled, solar-powered computer-based testing centers. Where required for exam integrity, this may include a government-issued ID number or photograph used solely to verify identity at the point of testing.
  • Payment and Donation Information. Billing name, billing address, and payment method details for Hub service fees, or donor name, contact information, and payment details for Foundation donations and grants. Payment card and mobile-money information is processed and stored by our third-party payment processors (e.g., Stripe, Paystack, or Flutterwave) and is not stored on our servers.
  • Community and Course Content. Coursework, assignments, project files, forum posts, comments, messages, images, videos, and any other content you upload or create through the Service.
  • Employment and Placement Information. Resumes, portfolios, and employment history you voluntarily submit through Foundation job-placement and entrepreneurship support services.
  • Information you provide when you contact our support team, respond to surveys, submit grievances, or communicate with us through any channel.
  1. b) Information Collected Automatically
  • Device Information. Device type, operating system, browser type and version, unique device identifiers, and mobile network information, including information from devices used at our solar-powered digital learning labs.
  • Usage Data. Pages viewed, courses accessed, features used, actions taken, time spent on the Service, access times, referring URLs, and clickstream data.
  • Log Data. IP addresses, server logs, error logs, power/connectivity uptime logs, and diagnostic data.
  • Cookies and Similar Technologies. We use cookies, local storage, and similar tracking technologies to maintain sessions, remember preferences, and analyze usage patterns. See Section 7 for more details.
  1. c) Information from Third Parties
  • Payment Processors. Transaction confirmation and billing or donation status from Stripe, Paystack, Flutterwave, or similar providers.
  • Government and Regulatory Bodies. Verification information from Nigeria’s Corporate Affairs Commission (CAC), the Cross River State Ministry of Education, or comparable authorities, where relevant to program accreditation or compliance.
  • Donors, Grantors, and Partner Organizations. Referral, sponsorship, or scholarship eligibility information provided by donors, grant-making institutions, or implementing partners.
  • Employers and Referral Partners. Feedback on job placements or apprenticeships arranged through our workforce-readiness programs.
  • Authentication Providers. If you sign in using a third-party service (e.g., Google Sign-In), we receive your name, email, and a unique identifier from that provider.
  1. How We Use Your Information

We use the information we collect for the following purposes:

  • Providing the Service. To enroll in programs, administer training curricula and assessments, issue certifications, host our digital community, process transactions and donations, and provide learner or client support.
  • Program Improvement and Impact Measurement. To analyze usage trends, diagnose technical or solar-power system issues, develop new curricula and features, and measure educational outcomes, employability, and entrepreneurship impact.
  • Grant and Donor Reporting. To prepare aggregate, de-identified impact reports for donors, grantors, and regulatory bodies documenting program reach and outcomes. We do not share individually identifiable beneficiary data with donors without your consent, except as required by a specific grant agreement and disclosed to you at enrollment.
  • To send program-related notifications (enrollment confirmations, exam schedules, certification results, billing receipts, security alerts, and system updates). We may also send promotional or fundraising communications, from which you can opt out at any time.
  • Security, Exam Integrity, and Fraud Prevention. To detect, investigate, and prevent fraudulent, unauthorized, or illegal activity, to safeguard the integrity of our technology-enabled assessments, and to protect the security of our Service, learners, and staff.
  • Legal and Regulatory Compliance. To comply with applicable Nigerian law (including the Nigeria Data Protection Act, 2023), U.S. federal tax-exemption requirements applicable to the Foundation, and other applicable laws, regulations, legal processes, or enforceable governmental requests.
  • Enforcing Our Policies. To enforce our Terms of Service, Acceptable Use Policy, Code of Conduct, and other program agreements.
  1. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

  • Between the Foundation and the Hub. Because the Foundation and the Hub operate as strategic, collaborating partners, certain operational, enrollment, and technical data (such as shared facility usage, IT systems, and cross-referrals between subsidized Foundation training and Hub commercial services) may be shared between the two entities as necessary to deliver the “One Mission, Two Paths” ecosystem. This data-sharing is governed by a written inter-entity agreement (the “Master Shared Services Agreement”), priced at fair market value and reviewed annually by the Foundation’s Audit & Compliance Committee. Each entity remains responsible for the data it independently controls, as described in Section 14.
  • Instructors, Mentors, and Program Administrators. Assigned trainers, mentors, and administrators may access your profile, coursework, and progress data as necessary to deliver training and support.
  • Service Providers. We share information with trusted third-party service providers who help us operate the Service, including cloud hosting, payment and donation processing (e.g., Stripe, Paystack, Flutterwave), solar-power and system monitoring vendors, learning-management and assessment platform vendors, email delivery, analytics, and support tools. These providers are contractually obligated to use your information only as necessary to provide services to us.
  • Donors, Grantors, and Regulatory Bodies. We may share aggregate or de-identified program data with donors, grant-making institutions, the Corporate Affairs Commission (CAC), the Nigeria Data Protection Commission (NDPC), the U.S. Internal Revenue Service, or other applicable regulators, as required for compliance, transparency, or grant reporting.
  • Employers and Placement Partners. With your consent, we may share your resume, certification, and qualification information with prospective employers or apprenticeship partners for job-placement purposes.
  • Legal Requirements. We may disclose your information if required to do so by law, or if we believe in good faith that such disclosure is necessary to comply with a legal obligation, protect our rights or safety, investigate fraud, or respond to a government request.
  • Business Transfers. In the event of a merger, acquisition, reorganization, or sale of all or a portion of the Hub’s assets, or a change in the Foundation’s fiscal sponsorship or corporate structure, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
  • With Your Consent. We may share your information for any other purpose with your explicit consent.
  1. Data Retention

We retain your personal information for as long as your account or enrollment is active, or as needed to provide you with the Service. We may also retain and use your information as necessary to:

  • Comply with legal obligations (e.g., Nigerian corporate and tax record-keeping requirements and U.S. 501(c)(3) recordkeeping and reporting obligations).
  • Satisfy donor and grant reporting and audit requirements.
  • Resolve disputes and enforce our agreements.
  • Maintain security and prevent fraud, including preserving assessment records to protect certification integrity.
  • Fulfill any other legitimate program or business purpose.

When your account is terminated or your program participation ends, we will delete or anonymize your personal information within a reasonable timeframe, unless retention is required or permitted by law, or required to preserve official certification and academic records. Certification and assessment records may be retained indefinitely to allow verification of credentials by employers or third parties.

  1. Data Security

We implement commercially reasonable technical, administrative, and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction, including in our off-grid, solar-powered operating environment. These measures include:

  • Encryption of data in transit using TLS/SSL.
  • Secure cloud infrastructure with redundant, solar-battery-backed local systems to maintain data integrity during low-sunlight or power-interruption periods.
  • Access controls limiting staff, instructor, and administrator access to personal data on a need-to-know basis.
  • Regular security assessments, system monitoring, and periodic offline data backups given the rural, low-connectivity operating context.

No method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security. You are responsible for maintaining the security of your account credentials.

  1. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information:

  • You may request a copy of the personal information we hold about you.
  • You may request that we correct inaccurate or incomplete personal information.
  • You may request that we delete your personal information, subject to certain legal and recordkeeping exceptions (see Section 4).
  • You may request a copy of your data in a structured, commonly used, machine-readable format.
  • Objection and Restriction. You may object to, or request restriction of, certain processing of your personal information.
  • Opt-Out of Marketing. You may opt out of receiving promotional or fundraising communications by following the unsubscribed instructions in those messages or by contacting us directly.
  • Push Notifications. You may disable push notifications through your device settings at any time.

To exercise any of these rights, please contact us using the details in Section 16. We will respond to your request within thirty (30) days, or such shorter period as required by applicable Nigerian or U.S. law.

  1. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Maintain your logged-in session and remember your preferences.
  • Analyze how the Service is used and measure program engagement and performance.
  • Ensure the security and integrity of the Service and our assessment platforms.

You can manage cookie preferences through your browser settings. Disabling cookies may affect the functionality of certain features of the Service, including online course access and testing modules. We do not currently respond to “Do Not Track” browser signals.

  1. Third-Party Links and Services

The Service may contain links to third-party websites, services, or applications (including donor portals, payment gateways, or employer sites) that are not operated by us. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party service you access. We are not responsible for the privacy practices or content of third-party services.

  1. Children’s and Minors’ Privacy

The Foundation’s youth-focused programs may serve individuals under the age of 18. Where a participant is a minor or otherwise lacks legal capacity to consent, we obtain verifiable consent from a parent or legal guardian before collecting or processing that minor’s personal data, consistent with the Nigeria Data Protection Act, 2023. We apply reasonable age-verification measures at enrollment.

Our general Hub commercial services and website are not directed to individuals under 18, and we do not knowingly collect personal information from children under 18 outside of the Foundation’s authorized youth programs. If we become aware that a child has provided personal information outside an authorized program without appropriate guardian consent, we will take steps to delete such information promptly. Parents or guardians with concerns should contact us using the details in Section 16.

  1. International Data Transfers

The Foundation is a U.S.-organized 501(c)(3) nonprofit, and the Hub operates in Nigeria; both entities primarily provide services within Boki LGA, Cross River State, Nigeria. Where necessary to operate the Service, provide U.S. tax-exemption reporting, engage cloud service providers, or coordinate with international donors, your information may be transferred to, stored, and processed in the United States or other countries, where data protection laws may differ from those in Nigeria. Any such cross-border transfer will be conducted in accordance with the Nigeria Data Protection Act, 2023, including the use of appropriate contractual or other safeguards where required. By using the Service, you consent to the transfer of your information as described in this Policy.

  1. Nigerian Data Protection Rights (NDPA)

As our programs and facilities are based in Boki LGA, Cross River State, Nigeria, we process personal data in accordance with the Nigeria Data Protection Act, 2023 (“NDPA”) and the oversight of the Nigeria Data Protection Commission (“NDPC”). Under the NDPA, you have the right to:

  • Obtain confirmation of, and access to, personal data we hold about you.
  • Request rectification or erasure of inaccurate, incomplete, or outdated personal data.
  • Request restriction of processing in certain circumstances.
  • Object to processing, including for direct marketing purposes.
  • Data portability, allowing you to obtain and transmit your data to another controller.
  • Withdraw consent to processing at any time, without affecting the lawfulness of prior processing.
  • Lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng if you believe your rights under the NDPA have been violated.

Where processing of your personal data relies on consent (including for minors, processed via parental or guardian consent as described in Section 9), you may withdraw that consent at any time by contacting us using the details in Section 16. NDPA-related requests may also be directed to our Data Protection & Safeguarding Officer once appointed (see Section 16).

  1. California Privacy Rights (CCPA)

If you are a California resident (for example, a U.S.-based donor or website visitor), you have additional rights under the California Consumer Privacy Act (CCPA):

  • The right to know what personal information we collect, use, and disclose about you.
  • The right to request deletion of your personal information.
  • The right to opt out of the sale of your personal information. We do not sell your personal information.
  • The right to non-discrimination for exercising your privacy rights.

To exercise your CCPA rights, contact us using the details in Section 16.

  1. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland (for example, an international donor or grant partner), we process your personal data on the following legal bases:

  • Contract Performance. Processing necessary to provide you with the Service or grant relationship you requested.
  • Legitimate Interests. Processing necessary for our legitimate interests, such as program integrity, fraud prevention, security, and service improvement, where those interests are not overridden by your rights.
  • Where you have given us consent to process your data for specific purposes (e.g., marketing or fundraising communications).
  • Legal Obligation. Processing is necessary to comply with applicable laws.

You have the right to access, rectify, erase, restrict processing, object to processing, and data portability. You also have the right to lodge a complaint with your local data protection authority. To exercise any of these rights, contact us using the details in Section 16.

  1. Roles and Responsibilities of the Foundation and the Hub

The Foundation and the Hub are separately organized entities that collaborate under the “One Mission, Two Paths” model but generally act as independent data controllers with respect to the personal data collected through their respective activities:

  • The Foundation acts as the data controller for all data collected through its subsidized charitable education, assessment, and vocational training programs, including beneficiary eligibility, donor, and grant-reporting data.
  • The Hub acts as the data controller for data collected through its commercial, market-rate digital and technology services, including client and billing data.
  • Where the Foundation and the Hub jointly operate shared infrastructure (such as the solar-powered digital learning and testing facility) or where a participant transitions between a subsidized Foundation program and a paid Hub service, the two entities may act as joint controllers for the limited data necessary to manage that shared facility or transition and will apportion responsibility for responding to data subject requests accordingly.
  • Each entity is responsible for maintaining appropriate safeguards, honoring data subject rights requests relating to data it controls, and complying with all applicable data protection laws, including the NDPA, GDPR, and CCPA, as relevant to its activities.
  1. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our programs, technologies, legal requirements, or other factors. When we make material changes, we will update the “Effective Date” at the top of this page and, where appropriate, notify you via email or through a notice on the Service.

Your continued use of the Service after any changes to this Policy constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically.

  1. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Boki Youth Development Foundation
Email: youth@bokiglobal.org

Address: No. 13 Okundi – Ogoja Hwy, Okundi – Boki LGA, Cross River State – Nigeria
P. O. Box 791, Ogoja – Cross River State, Nigeria

U.S. Incorporation: Nonprofit corporation, State of Minnesota
U.S. Tax-Exempt Status: Section 501(c)(3) application filed; IRS determination pending. EIN 42-4002034

Boki Technology Hub
Email: tech@bokiglobal.org

Address: No. 13 Okundi – Ogoja Hwy, Okundi – Boki LGA, Cross River State – Nigeria
P. O. Box 791, Ogoja – Cross River State, Nigeria

 CAC Registration No.:9566820

Website: https://bokiglobal.org 

By using the Boki Youth Development Foundation and Boki Technology Hub Service, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.