This Privacy Policy was last updated September 2023.

The policy relates to the GMN Academy platform and all user data collected and managed through the platform to deliver GMN Academy Services. If you use GMN Academy Services (a “User”) this policy applies to you and you are bound by it. If you disagree, you are encouraged to terminate your account with GMN Academy Services.

  1. Our commitment
    GM Networkx Limited trades as “GMN Academy”, and is located in Abuja, Nigeria. GMN Academy respects User’s rights regarding privacy and information, taking great care with any personally identifying information. As a Nigerian domiciled entity, the GMN Academy platform is subject to the laws and regulation of Nigeria. The General Data Protection Regulation in Nigeria applies to the safeguarding and processing of personal data that could be used to identify any citizen of Nigeria. GMN Academy is committed to complying with its legal obligations in this regard, not just to data subjects (Users) in Nigeria-Africa but to extend the same courtesy to all GMN Academy Users worldwide.

This policy is based on obligations created through General Data Protection Regulation in Nigeria and other equivalent legislation worldwide such as the Consumer Privacy Act in the US.

  1. Collection, processing and storage of data
    The GMN Academy platform may collect and process personal data relating to past and present users and learners in the course of business. GMN Academy collects data directly from the User input but also in automated ways such as through system logs, cookies, web beacons and integration with third party service providers. Processing of data includes: collecting; recording; storing; altering; disclosing; destroying; and blocking. This policy governs GMN Academy’s approach to data and does not apply to any third party organisations which may have integrated their systems to the GMN Academy platform.
  2. Personally Identifying Information
    Personally Identifying Information may be required to uniquely identify a User upon Registration (e.g. a personal email address) and other information may be required to complete purchases and receive certification if requested. You may also be invited to create a personal profile and resumé (including date of birth, existing education, work experience and career ambitions) and to generate or supply other personal information (such as completing personality, psychometric and workplace assessments) to build your profile and determine your suitability for different careers, job opportunities, and also to establish your own tailored learning pathway. You will have the option to share or unshare some or all of this information in your own public profile.

Personal data is stored within your User account on the platform and access is completely restricted via encrypted networks and access permissions in order to ensure the highest levels of confidentiality and protection. No personal data is available to download or remove from the platform by employees or third parties, and GMN Academy ensures that only authorised personnel have online access to a User’s account data.

Users may decide to post comments on the GMN Academy Blog or interact with other Users in a way which is public or widely available to GMN Academy Users through postings, sharing, course reviews, direct communications, giving testimonials, uploading photos or commenting on different parts of the GMN Academy platform (“Shared Content” or “Public Posting”). GMN Academy will collect and store Public Postings and Shared Content which will become publicly available or viewable by others. When you share content or make a public posting you are consenting to granting GMN Academy a non-exclusive right and license to reproduce, distribute, publicly perform, offer, market and otherwise use and exploit the Public Postings and Shared Content. However GMN Academy is not responsible for how other Users may use such publicly available information or otherwise accessible to others who have access to the Services. Users are expected to use their discretion when making such posts. In the event that a User is selected as “Learner of the Day” or “Learner of the Month”, the User agrees to allow GMN Academy to publish their Registration Information (except for your email address), Profile Information, and Course Information as well as your response to the accolade for marketing purposes via GMN Academy Services.

  1. Course information
    After registration, a User can enroll in a course offered by GMN Academy or its affiliated Publishers. Aggregated data on age, gender (where available) and country of origin is shared with affiliated Publishers relating to the Users enrolled on the courses they teach, and is subject to a legal agreement between GMN Academy and each individual Publisher. There is no way for a Publisher to access or derive User level information from this aggregated information.

GMN Academy processes certain data relevant to the publication and playback of course content by publishers and learners. Certain data is collected to ensure Users, publishers and learner progress are uniquely identified and accurate records are maintained in order to deliver the GMN Academy learning service and to comply with relevant legal obligations. This will include regular emails to keep Users informed of their progress and make various suggestions and recommendations. Patterns of usage behaviour and course content evaluation is also collected and stored as metadata to help GMN Academy and Publishers improve the services and offer the most appropriate content and courses to registered Users.

  1. Third party information processors and service providers
    All User personal data is stored securely on third party cloud-based electronic storage and safeguarded. User purchases of physical goods require a home delivery address to process orders. GMN Academy uses payment processing and fulfillment partners who will receive sensitive PII to enable payment collection and when necessary, physical fulfillment. Highly sensitive data, such as credit card information and passwords are never received by GMN Academy (e.g. when you allow third party authentication via your social media sign-on, or by choosing third party payment providers such as Paypal or Stripe, that isolate GMN Academy from your payment details). Recurring payment details are stored by a third party payment provider that you choose and not by GMN Academy. Although GMN Academy allows Users to register with their social media single sign-on (such as Facebook, Google, Linked-in etc.) the information available on these third party platforms is governed by their terms and information sharing practices. GMN Academy only takes necessary information from these social platforms (i.e. your name, email address, and country for legitimate purposes) and does NOT take any other personal or social information on your friends and contacts from these platforms.

GMN Academy tests and operates a number of analytical tags, scripts and tracking pixels (also known as web beacons) from third party providers such as Google, Facebook, Bing, and Hotjar to enable browser and mobile analytics that measure page views and sessions. This helps GMN Academy understand User behaviours as they visit, navigate and leave the GMN Academy platform.

6. Technical data collection
As an internet based service, web server log files are also collected and monitored for usage and behaviour patterns over time. User device information and IP addresses are also collected to understand platform traffic flows, how each User interacts with GMN Academy Services, as well as to ensure the right balance of technical support, customer service resources and device expertise is available to Users.

GMN Academy also stores and uses cookie information (a piece of text saved on each User’s device) to help track unique user sessions in order to personalise GMN Academy Services for the User. GMN Academy stores Preference, Security, Functional and Session cookies to tailor the usage experience, securely automate User login and enable purchase transactions. GMN Academy uses web beacons to help monitor email communications with our registered Users to understand which messages are successfully delivered and read.

  1. User consent and self-service control
    By using GMN Academy Services and directly inputting your information on the platform, you the User are consenting to the collection and use of your data by GMN Academy. You have full access to your information through your user account, and are responsible for ensuring that you keep your personal details up-to-date through the platform. You have the power to modify your personal data and the power to deactivate your account and request the removal of your personally identifiable information when you delete your account. You may modify your email client, browser settings or use browser add-ons to control how cookies, beacons and other third party services work. Privacy settings are also provided on your mobile device operating system to give you more control over your data. Reducing the level of data shared may reduce the quality of, or disable, some or all GMN Academy services.

GMN Academy recognises the privacy interests of children. Parents and guardians need to take an active role in their children’s online activities and interests. Digital consent is generally not legally recognised for children under the age of 16 where such children reside in the Nigeria-Africa Economic Area. Parents and legal guardians should not allow their children defined as such to register, enrol and learn on the GMN Academy platform without full time supervision. GMN Academy reserves the right to delete any User account that we discover was created by a child unable to give digital consent. If a parent or guardian discovers that GMN Academy has unlawfully collected the personal information from a child please contact our data protection officers who will take all reasonable steps to delete such information promptly.

  1. Retention of data
    GMN Academy is under a legal obligation to keep certain data for a specified period of time. Furthermore GMN Academy aggregates data and anonymises User accounts that are deleted so that it is no longer reasonably associated with an identified or identifiable natural person. Such Other Information is used by GMN Academy for other relevant business purposes for as long as necessary. This may include keeping Other Information after the User has deleted their account for whatever period of time needed for GMN Academy to pursue its legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce commercial agreements.
  2. Security and disclosure of data
    The organisation will take all reasonable steps to ensure that appropriate security measures are in place to protect the confidentiality of electronically stored data. The platform is large and public and subject to regular attack by hackers. The platform has been hardened extensively over time, however no online system is perfect or immune from breach. GMN Academy has appropriate security measures in place to protect against unauthorised access. Safeguards are applied to the processing and retention of data. These include:
    Limitations on access to prevent unauthorised consultation, alteration, disclosure or erasure of personal data.
    Strict time limits for erasure of personal data in line with our retention policy.
    Logging mechanisms to permit verification of whether and by whom personal data has been consulted, altered, disclosed or erased.
    Pseudonymisation, anonymisation and encryption.
    The platform databases are not accessible directly by employees or software developers other than authorised DevOps administrators. Multi factor authentication is required for all authorised DevOps administrators to ensure access to sensitive data is restricted to the maximum possible.
    Security measures will be reviewed from time to time, having regard to the technology available, the cost and the risk of unauthorised access.

Customer Support employees will have access to a certain amount of personal data relating to users and other third parties. Employees must not disclose User’s personal data, except where necessary in the course of their employment or in accordance with law. They must not remove or destroy personal data except for lawful reasons and with the permission of the organisation. Any breach of the data protection principle is a serious matter and may lead to disciplinary action up to and including dismissal. All GMN Academy employees must adhere to the following data protection principles:

Process data fairly, lawfully and transparently.
Keep data only for specified, explicit and legitimate purposes.
Process data only in ways which are compatible with the purposes for which it was given.
Ensure data is accurate and up-to-date.
Ensure data is adequate, relevant and limited to what is necessary for the purpose for which it was given.
Keep data safely and securely.
Retain personal data for no longer than is necessary for the purpose for which it is processed and in line with the company’s data retention policy.
Users have an obligation to keep their User account credential sufficiently strong, protected for safe-keeping and private to themselves to prevent unauthorised access. Users must monitor and control all activity on their account. If you suspect a breach of your account please change your password immediately and contact GMN Academy customer support so that the impact can be minimised.

Were a data breach to occur and if such a breach puts individuals’ personal rights and freedom at risk and GMN Academy is unable to contain those risks, all affected individuals will be notified expeditiously. Furthermore GMN Academy’s data protection officers will inform the Data Protection Commissioner in Nigeria so that they are aware and can monitor the response.

  1. Data Protection Officers
    The directors of the company are ultimately responsible for your data, and have nominated a named Data Protection Officer for GMN Academy. The DPO is (are) responsible for assisting the organisation in monitoring and maintaining compliance with data protection legislation.

Please email your data protection and privacy queries or concerns to

  1. Access requests
    Users across the world may have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. Your GMN Academy User Account provides the settings and self-service tools needed for these requests. Please contact GMN Academy Customer Services if you wish to get a complete copy of all your electronic data held about you as a User. If a User opts to delete their User account, GMN Academy will delete all PII, Profile and Resumé data, and will irreversibly anonymise their learner record.

There is no charge to use GMN Academy’s User account self-service tools. However the company reserves the right to charge a fee to process any further Subject Access Request. The organisation will, in most circumstances, provide this data within one month. In some cases, due to the complexity of the request or the number of requests being handled by the organisation, the organisation may require a further 90 days to provide this data.

Users are only entitled to access data about themselves and will not be provided with data relating to other users or third parties. However some user data may have been disclosed publicly on GMN Academy forums for example. It may be possible to block out User data relating to a third party or conceal the User’s identity, and where this is possible the organisation will endeavour to do so. A user who is dissatisfied with the outcome of an access request has the option of referring a complaint to the office of the Data Protection Commissioner in Nigeria.

  1. Right to object
    Users may have the right to object to data processing that is causing them distress and/or to make corrections to personal data which is inaccurate. Where such objection is justified, the organisation will cease processing the data unless it has a legitimate interest that prevents this. GMN Academy will make every effort to alleviate the distress caused to the individual. An objection should be made in writing to the Data Protection Officer, outlining the data in question and the harm being caused.
  2. International transmission of data
    Based in the Federal Republic of Nigeria, GMN Academy operates on a global basis and it may be necessary in the course of business to collect or transfer User personal data across state boundaries, to share data with other group companies in countries outside the Nigeria – Africa Economic Area, and to share information with third party service providers. The transfer of such data is deemed necessary for the management and administration of your User Account and delivery of GMN Academy Services. Some states do not have comparable data protection laws to Nigeria or the OAU. When data transfer is necessary, GMN Academy will take steps to ensure that the data has an equal level of protection as it would in Nigeria or as expected within other leading international jurisdictions. Furthermore, GMN Academy will only transmit data to companies that agree to guarantee the same level of protection. For more information, please contact GMN Academy’s Data Protection Officers.
  3. Policy review and modification
    GMN Academy has completed a Data Protection Impact Assessment and put the necessary policy and procedures in place to minimise risks to users’ data privacy and maximise data protection. This policy will be reviewed from time to time to take into account changes in the law and the experience of the policy in practice. Updates will be posted to the website when available. Material updates will be circulated to each User via the registered User email on the User Account. Continued usage of the GMN Academy Service is deemed to be the User’s acceptance of this policy as permitted by applicable law.

GMN Academy Cookies Policy
Effective Date: September, 2023

What are cookies?
Cookies are small text files placed onto your computer or device as you browse the Internet. Cookies can be used to collect, store and share bits of information about your activities across websites and services, including on GMN Academy. They also allow us to remember things about your visit to GMN Academy, such as your preferred language and other choices/settings and generally make the site easier for you to use.

GMN Academy uses both session cookies and persistent cookies. A session cookie is used to identify a particular visit to GMN Academy. These cookies expire after a short time, or when you close your web browser after using GMN Academy. We use these cookies to identify you during a single browsing session, such as when you log into GMN Academy. A persistent cookie will remain on your devices for a set period of time specified in the cookie. We use these cookies when we need to identify you over a longer period of time. For example, we would use a persistent cookie if you asked that we keep you signed in.

Why does GMN Academy use cookies and similar technologies?
GMN Academy uses cookies and similar technologies, such as web beacons, browser cookies, pixel tags, or local shared objects to deliver, measure, and improve our services in various ways. We use cookies both when you access our site and services on a browser, as well as through our native mobile app. As we adopt additional technologies, we may also gather additional information through other methods.

We use cookies for the following purposes:
Authentication and security:
To log you into GMN Academy;
To protect your security;
To help us detect and fight spam, abuse, and other activities that violate GMN Academy’s agreements and terms.

To remember information about your browser and your preferences;
To remember your settings and other choices you have made.
For example, cookies help us remember your preferred language or the country that you are in. We can then provide you with content in your preferred language without having to ask you each time you visit GMN Academy.

Analytics and research:
To help us improve and understand how people use GMN Academy.
For example, cookies help us test different versions of GMN Academy to see which particular features or content users prefer. We may include web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics. We might also optimize and improve your experience on GMN Academy by using cookies to see how you interact with GMN Academy, such as when and how often you use them and what links you click on.

To help us better understand how people use GMN Academy, we work with a number of analytics partners, including Google Analytics. These providers use cookies and similar technologies to help us analyze how users use the Services, including by noting the third-party Services from which you arrive. The information collected will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of GMN Academy. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out plugin.

We don’t release the information collected from our own cookies to any third parties, other than to our service providers who assist us in these activities.

Personalized content: To customize GMN Academy with more relevant content.

What are my privacy options?
You have a number of options to control or limit how we and our partners use cookies.
This cookie policy is available at our site. By continuing to use or access GMN Academy, you are consenting to our use of cookies and related technologies as described in this Cookies Policy.
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of GMN Academy.
Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
Changes to this Policy
We will notify you of any changes by posting the new Policy on GMN Academy with a new effective date. If we make a material change to this Policy, we will take reasonable steps to notify you in advance of the planned change.

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