Privacy Policy

This Privacy Policy explains how Tochukwu Nkwocha and tochukwunkwocha.com ("we", "us", "our") collect, use, disclose, and protect your personal information when you visit our website, enrol in courses, make a payment, upload payment proof for manual verification, or join our email lists.

1. Information We Collect

We may collect the following categories of personal information:

• Identity and contact information: first name, email address, country, and related profile details.
• Transaction information: order ID, course, payment status, currency, amount, and payment channel.
• Manual transfer information: proof-of-payment files and transfer metadata you submit for verification.
• Technical information: device/browser information, IP address, pages viewed, and event logs.
• Marketing and communication information: subscription preferences and campaign interactions.

2. How We Collect Information

• Directly from you when you fill forms, enrol, pay, or contact us.
• Automatically through site technologies (for example, server logs and conversion/event tools).
• From payment partners when a transaction is processed or verified.

3. How We Use Information

• Provide and manage course enrolment and course-related communication.
• Process payments and confirm transaction status.
• Handle manual transfer verification and enrolment queue management.
• Send onboarding, transactional, and marketing emails (where permitted).
• Maintain security, prevent abuse/fraud, and resolve disputes.
• Improve website performance, content quality, and learner experience.
• Comply with legal obligations and enforce our terms.

4. Payment Processing

We use third-party payment processors including Paystack and PayPal. Card/payment account details are handled by those processors under their own privacy policies and compliance controls. We do not store full payment card details on our servers.

5. Manual Bank Transfer Verification

Where you choose manual bank transfer, we collect the payment proof you upload to verify your transfer before full enrolment. On submission, your contact may be added to a pre-enrolment communication segment. After payment is manually confirmed, your contact may be moved to the main enrolment segment.

6. Email and CRM Providers

We use third-party email/CRM providers (including Flodesk) to manage enrolment communication, updates, and announcements. Your data is processed by these providers under their own terms and privacy notices.

7. Analytics and Advertising

We may use analytics and event tracking tools to understand page usage and campaign performance. These tools may use cookies or similar technologies. You can restrict cookies in your browser settings, though some site features may be affected.

8. Legal Bases (UK/EU Users)

Where applicable, we process personal data under one or more lawful bases:

• Performance of a contract (for enrolment and payment fulfilment).
• Legitimate interests (security, service improvement, fraud prevention, operations).
• Consent (for certain marketing communications or optional tracking, where required).
• Legal obligation (recordkeeping, compliance, and law-enforcement requests).

9. Data Sharing

We may share personal data with:

• Payment processors and financial service providers.
• Cloud hosting/storage and infrastructure providers.
• Email delivery/CRM/marketing providers.
• Professional advisers, regulators, and authorities when legally required.

We do not sell personal data in exchange for monetary consideration.

10. International Transfers

Because our service providers may operate in multiple countries, your data may be processed outside your home jurisdiction. Where required, we rely on appropriate safeguards under applicable law.

11. Data Retention

We retain data only for as long as reasonably necessary for the purposes in this policy, including legal, tax, accounting, operational, and dispute-resolution requirements.

12. Security

We use reasonable administrative, technical, and organizational safeguards to protect personal data. No internet or storage system is guaranteed to be 100% secure.

13. Your Rights

Depending on your location, you may have rights to:

• Access, correct, update, or delete your personal data.
• Object to or restrict certain processing.
• Withdraw consent where processing depends on consent.
• Request portability of data where applicable.
• Complain to a data protection authority.

14. Children’s Privacy

Our services are not directed to children under 13. We do not knowingly collect personal data from children under 13 without appropriate authorization.

15. Third-Party Links

Our site may link to third-party websites/platforms. We are not responsible for the privacy practices of third-party services.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the "Last updated" date and publishing the revised version on this page.

17. Contact

For privacy questions or requests, contact: tochukwu@sureimports.com