We value your privacy. This privacy policy
explains personal data that Cinfores Limited collect when using our product and services,
how we process it and for what purpose it is used including how we protect your data both in
storage and transit.
Information We Collect
Information you provide to
us:: We collect information about you when you input it into the Services or otherwise
provide it directly to us
Account and Profile
Information:: We collect information about you when you register for an account, create
or modify your profile, set preferences, sign-up for or make purchases through the Services we
provide such as brain friend.
Content you provide through
our products:: The Services include the content and assessment products you use; the
software service we manage on behalf of our clients as processors. We also collect and store
content that you post, send, receive and share in our platforms. This content includes any
information about you that you may choose to include.
Information you provide
through our support channels:: The Services also include our customer support, where you
may choose to submit information regarding a problem you are experiencing with a Service.
Cookies and Other Tracking
Technologies:: Our products including websites do not use cookies at the moment
Information we receive from
other sources :: We collect information about you when you input it into the Services or
otherwise provide it directly to us
Third Party Providers::
We may receive information about you from third party providers of business information and
publicly available sources (like social media platforms), including physical mail addresses, job
titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses and
social media profiles, for the purposes of targeted advertising of products that may interest
you, delivering personalized communications, event promotion, and profiling
How we use Information We Collect
How we use the information we
collect depends in part on which Services you use, how you use them, and any preferences you
have communicated to us. Below are the specific purposes for which we use the information we
collect about you
To provide the Services and
personalize your experience: We use information about you to provide the Services to
you, including to process transactions with you, authenticate you when you log in, provide
customer support, operate, maintain, and improve the Services.
For research and
development: We are always looking for ways to make our Services smarter, faster,
secure, integrated, and useful. We use information including feedback about how people use our
Services to troubleshoot, to identify trends, usage, activity patterns, and areas for
integration and to improve our Services and to develop new products, features and technologies
that benefit our users and the public
To communicate with you
about the Services : We use your contact information to send transactional
communications via email and within the Services, including confirming your purchases, reminding
you of subscription expirations, responding to your comments, questions and requests, providing
customer support, and sending you technical notices, updates, security alerts, and
administrative messages
To market, promote and drive
engagement with the Services: We may use your contact information and information about
how you use our services to send promotional communications that may be of specific interest to
you.
Customer support : We
use your information to resolve technical issues you encounter, to respond to your requests for
assistance, to analyze information, and to repair and improve the Services. Where you give us
express permission to do so, we share information with a third party expert for the purpose of
responding to support-related requests.
For safety and security :
We use information about you and your Service to verify accounts and activity, to detect,
prevent, and respond to potential or actual security incidents and to monitor and protect
against other malicious, deceptive, fraudulent or illegal activity, including violations of
Service policies
To protect our legitimate
business interests and legal rights : Where required by law or where we believe it is
necessary to protect our legal rights, interests and the interests of others, we use information
about you in connection with legal claims, compliance, regulatory, and audit functions,
and disclosures in connection with the acquisition, merger or sale of a business
With your consent: We
use information about you where you have given us consent to do so for a specific purpose not
listed above. For example, we may publish testimonials or featured customer stories to promote
the Services, with your permission
How we share Information We Collect
We share information we collect
about you in the ways discussed below, including in connection with possible business transfers;
Sharing with other Service
users: When you use our services, we share certain information about you with other
service users
For collaboration: You
can create content, which may contain information about you, and grant permission to others to
see, share, edit, copy and download that content based on settings you or your administrator (if
applicable) select
Managed accounts and
administrators: If you register or access the Services using an email address with a
domain that is owned by your employer or organization or associate that email address with your
existing account, and such organization wishes to establish an account or site, certain
information about you including your name, profile picture, contact info, content and past use
of your account may become accessible to that organization’s administrator and other Service
users sharing the same domain. If you are an administrator for a particular site or group of
users within the Services, we may share your contact information with current or past Service
users, for the purpose of facilitating Service-related requests.
Community Forums: We may
collaborate with other companies, government agencies for forums and your personal data may be
shared to facilitate the program.
Sharing with third parties:
We may share information with third parties that help us operate, provide, improve,
integrate, customize, support and market our services
Service Providers:
We may work with third-party service providers to provide website and application development,
hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and
other services for us, which may require them to access or use information about you. If a
service provider needs to access information about you to perform services on our behalf, they
do so under close instruction from us, including appropriate security and
confidentiality procedures designed to protect your information.
Third Party Apps: You,
your administrator or other Service users may choose to add new functionality or change the
behavior of the Services by installing third party apps within the Services. Doing so may give
third-party apps access to your account and information about you like your name and email
address, and any content you choose to use in connection with those apps. If you are an
administrator, or a technical or billing contact listed on an account, we share your details
with the third-party app provider upon installation. Third-party app policies and procedures are
not controlled by us, and this privacy policy does not cover how third-party apps use your
information. We encourage you to review the privacy policies of third parties before connecting
to or using their applications or services to learn more about their privacy and information
handling practices. If you object to information about you being shared with these third
parties, please uninstall the app.
Links to Third Party Sites:
The Services may include links that direct you to other websites or services whose privacy
practices may differ from ours. If you submit information to any of those third party sites,
your information is governed by their privacy policies, not this one. We encourage you to
carefully read the privacy policy of any website you visit.
Social Media Widgets:
The Services may include links that direct you to other websites or services whose privacy
practices may differ from ours. Your use of and any information you submit to any of those
third-party sites is governed by their privacy policies, not this one.
With your consent: We
share information about you with third parties when you give us consent to do so. For example,
we often display personal testimonials of satisfied customers on our public websites. With your
consent, we may post your name alongside the testimonial.
Sharing with affiliated
companies: We share information we collect with affiliated companies and, in some cases,
with prospective affiliates. Affiliated companies are companies owned or operated by us. The
protections of this privacy policy apply to the information we share in these circumstances
Business Transfers: We
may share or transfer information we collect under this privacy policy in connection with any
merger, sale of company assets, financing, or acquisition of all or a portion of our business to
another company. You will be notified via email and/or a prominent notice on the Services if a
transaction takes place, as well as any choices you may have regarding your information
How we store and secure information we collect
The information we collect from you are stored and secured using various medium as stated below;
Information storage and
security: We use industry standard technical and organizational measures to secure the
information we store and transmit. We are implementing the requirements of ISO 27001: 2013 for
information security and ISO 27018 for cloud PII as well as complying with Nigerian Data
Protection Regulation 2019
How long we keep information
How long we keep information we collect about you depends on the type of information, as
described in further detail below. After such time, we will either delete or anonymize your
information or, if this is not possible (for example, because the information has been stored in
backup archives), then we will securely store your information and isolate it from any further
use until deletion is possible.
Account information:
We retain your account information for as long as your account is active and a reasonable
period thereafter in case you decide to re-activate the Services. We also retain some of your
information as necessary to comply with our legal obligations, to resolve disputes, to enforce
our agreements, to support business operations, and to continue to develop and improve our
Services. Where we retain information for Service improvement and development, we take steps to
eliminate information that directly identifies you, and we only use the information to uncover
collective insights about the use of our Services, not to specifically analyze personal
characteristics about you
Information you share on the
Services: If your account is deactivated or disabled, some of your information and the
content you have provided will remain in order to allow your team members or other users to make
full use of the Services.
Managed accounts: If
the Services are made available to you through an organization (e.g., your employer), we retain
your information as long as required by the administrator of your account
Marketing information:
If you have elected to receive marketing emails from us, we retain information about your
marketing preferences for a reasonable period of time from the date you last expressed interest
in our Services
How long we keep information
You have certain choices available to you when it comes to your information. Below is a summary
of those choices, how to exercise them and any limitations
You have the right to request a
copy of your information, to object to our use of your information (including for marketing
purposes), to request the deletion or restriction of your information, or to request your
information in a structured, electronic format. To do this use data subject access request
system. Your request and choices may be limited in certain cases: for example, if fulfilling
your request would reveal information about another person, or if you ask to delete information
which we or your administrator are permitted by law or have compelling legitimate interests to
keep. Where you have asked us to share data with third parties, for example, by installing
third-party apps, you will need to contact those third-party service providers directly to have
your information deleted or otherwise restricted. If you have unresolved concerns, you may have
the right to complain directly to NITDA
Our Services and related
documentation give you the ability to access and update certain information about you from
within the Service. For example, you can access your profile information from your account and
search for content containing information about you using key word searches in the Service. You
can update your profile information within your profile settings and modify content that
contains information about you using the editing tools associated with that content
Deactivate your account
If you no longer wish to use our Services, you or your administrator may be able to
deactivate your Services account. If you can deactivate your own account, that setting
is available to you in your account settings. Otherwise, please contact your administrator. If
you are an administrator and are unable to deactivate an account through your administrator
settings, please contact the appropriate support team. Please be aware that deactivating your
account does not delete your information; your information remains visible to other Service
users based on your past participation within the Services.
Delete your information:
Our Services and related documentation give you the ability to delete certain information
about you from within the Service. For example, you can remove content that contains information
about you using the key word search and editing tools associated with that content, and you can
remove certain profile information within your profile settings. Please note, however, that we
may need to retain certain information for record keeping purposes, to complete transactions or
to comply with our legal obligations.
Request that we stop using
your information: In some cases, you may ask us to stop accessing, storing, using and
otherwise processing your information where you believe we don't have the appropriate rights to
do so. For example, if you believe a Services account was created for you without your
permission or you are no longer an active user, you can request that we delete your account as
provided in this policy. Where you gave us consent to use your information for a limited
purpose, you can contact us to withdraw that consent, but this will not affect any processing
that has already taken place at the time. You can also opt-out of our use of your information
for marketing purposes by contacting us, as provided below. When you make such requests, we may
need time to investigate and facilitate your request. If there is delay or dispute as to
whether we have the right to continue using your information, we will restrict any further use
of your information until the request is honored or the dispute is resolved, provided your
administrator does not object (where applicable). If you object to information about you being
shared with a third-party app, please disable the app or contact your administrator to do so.
Opt out of communications:
You may opt out of receiving promotional communications from us by using the unsubscribe
link within each email, updating your email preferences within your Service account settings
menu, or by contacting us as provided below to have your contact information removed from our
promotional email list or registration database. Even after you opt out from receiving
promotional messages from us, you will continue to receive transactional messages from us
regarding our Services. You can opt out of some notification messages in your account settings
Data portability: Data
portability is the ability to obtain some of your information in a format you can move from one
service provider to another (for instance, when you transfer your mobile phone number to another
carrier). Depending on the context, this applies to some of your information, but not to all of
your information. Should you request it, we will provide you with an electronic file of your
basic account information and the information you create on the spaces under your sole control.
How we transfer information internationally
We collect information globally and may transfer, process and store your information outside of
your country of residence, to wherever we or our third-party service providers operate for the
purpose of providing you the Services. Whenever we transfer your information, we take steps to
protect it.
Other important privacy information
Many of our products are intended for use by organizations. Where the Services are made
available to you through an organization (e.g. your employer), that organization is the
administrator of the Services and is responsible for the accounts and/or Service sites over
which it has control. If this is the case, please direct your data privacy questions to your
administrator, as your use of the Services is subject to that organization's policies. We are
not responsible for the privacy or security practices of an administrator's organization, which
may be different than this policy.
Administrators are able to:
1. Require you to reset your account password;
2. Rrestrict, suspend or terminate your access to the Services;
3. Access information in and about your account;
4. Access or retain information stored as part of your account;
5. Install or uninstall third-party apps or other integrations
In some cases, administrators can also:
1. Restrict, suspend or terminate your account access;
2. Change the email address associated with your account;
3. Change your information, including profile information;
restrict your ability to edit, restrict, modify or delete information
Even if the Services are not currently administered to you by an organization, if you are a
member of a support team administered by an organization, or if you use an email address
provided by an organization (such as your work email address) to access the Services, then the
owner of the domain associated with your email address (e.g. your employer) may assert
administrative control over your account and use of the Services at a later date. You will be
notified if this happens.
Our policy towards children
Our Services such as BrainFriend are directed to individuals under 13 and we take step to ensure
security of these data about children.
Changes to our Privacy Policy
We may change this privacy policy from time to time. We will post any privacy policy changes on
this page and, if the changes are significant, we will provide a more prominent notice by adding
a notice on the Services homepages, login screens, or by sending you an email notification.
We will also keep prior versions of this Privacy Policy in an archive for your review.
We encourage you to review our privacy policy whenever you use the Services to stay informed
about our information practices and the ways you can help protect your privacy.
If you disagree with any changes to this privacy policy, you will need to stop using the
Services and deactivate your account(s), as outlined above.
Contact Us
If you have questions or concerns about how your information is handled, please direct your
inquiry to
BrainFriend is Nigeria's foremost e-learning and
examination preparatory tool. It is endorsed by the Federal Ministry of Education. It
complements classroom learning as well as serves as an examination preparatory tool. The
software package is developed to aid all students/pupils ranging from primary through the senior
secondary and post-secondary schools.