Privacy Policy

Provsy is an assessment platform for schools, operated by Provsy Innovations Limited, a company incorporated in the Federal Republic of Nigeria with its office in Abuja, Nigeria ("Provsy", "we", "us"). Schools use Provsy to build and mark assessments, keep score records, compute term report cards, and keep parents and guardians informed through progress reports.

This Privacy Policy explains what personal data we collect, why we collect it, who we share it with, how long we keep it, and the rights you have over it. It applies to the Provsy website (provsy.com), the school console, the teacher workspace, the learner portal, and every email, PDF or WhatsApp message we send on a school's behalf.

Because Provsy handles the school records of children, we have written this policy to be read by four different people: the school administrator who signs up, the teacher who marks a paper, the learner who logs in to revise, and the parent or guardian who receives a report. Where a section applies to only one of you, it says so.

Provsy is governed by the Nigeria Data Protection Act 2023 (NDPA) and, where a school is established in the United Kingdom or the European Economic Area, by the UK GDPR or EU GDPR as applicable. We do not claim compliance with laws that do not apply to us, and we will not tell you a school record is protected by a regime it is not.

When a school onboards its teachers and learners onto Provsy, it decides what is recorded about them and why. For the personal data of learners, guardians and teachers, the school is the data controller and Provsy is a data processor acting on the school's documented instructions under our Terms and Conditions and our data processing terms.

Provsy is the data controller for a narrower set of data: the account details of the person who registers a school, enquiries sent through our website, billing records, security and audit logs, and analytics about how the website itself is used.

This distinction matters in practice. If you are a parent and want to correct your child's name on a report card, stop receiving reports, or find out why your number is on file, the school holds that decision and we will route your request to it. If you are a school and need a signed data processing agreement, ask us at the address at the end of this policy.

We collect only what the product needs to function. Provsy does not ask for dates of birth, home addresses, national identity numbers or health information about learners, and the roster tools do not provide a place to store them. The one optional image is a passport photograph, described below.

Schools and school administrators

• Account. School name, the administrator's email address and password (stored only as a salted hash), the school's country and chosen academic system, academic year and term.
• School profile. School logo, address, school code, and the name, email address and phone number of the head of school.
• Enquiries. If you use our Get Started or Contact forms: your name, email, phone, school size, what you are hoping to solve, and how you heard of us.
• Billing and settlement. Plan, add-ons, term and payment history. If your school chooses to collect a Student Tech Fee through Provsy, we store the bank name, account number, account name and the payment-processor sub-account reference you give us so that fees are settled to the school. We never see or store card numbers.
• Configuration. Your school's settings, for example whether learners may register themselves, whether results are visible immediately, and assessment duration and lateness rules.

Teachers

• Full name, email address, phone number, password (hashed), the school you belong to and the subjects you teach.
• The papers you build, the marking you do, the scores you record for classwork, homework, practicals and projects, and the PDFs delivered to you.

Learners

• Roster record. Full name, the school's own student ID or admission number, class level and arm, school code, active status, academic year and term. Every learner has this record, whether or not they ever log in.
• Passport photograph (optional). A school or the learner's class teacher may upload a passport-style photograph of the learner. It appears on the report card only if the school has switched that on in its settings, which is off by default, and it can be removed at any time. We do not use it for anything else, and we do not perform facial recognition.
• Portal account. Where the school's plan includes the learner portal and the learner is given access: an email address and password (hashed), onboarding status, and the level and graduation confirmations the learner makes.
• Assessment data. Answers, attempts, marks, grades, submission times, and whether a paper was sat on paper or online. This is the material of a report card and is retained as a school record.
• Learning activity. Revision material opened, flashcards and practice quizzes attempted, podcasts generated, trivia points, games and tournament results, and "Teach Me" or "Explain like I'm five" conversations with the AI tutor where the school has enabled it.
• Readiness and insight. Predictive readiness scores and progress summaries derived from the above.

Parents and guardians

• For up to two guardians per learner, depending on the school's plan: name, email address, and whether that address has been verified with a one-time code.
• Where WhatsApp delivery is offered: the guardian's phone number, the date and time consent to receive WhatsApp messages was given, and whether the number was verified by a one-time code sent to it on WhatsApp.
• Nothing is sent to an email address or WhatsApp number until the guardian has confirmed it with a code we sent to that address or number. If a message later bounces, the contact is automatically marked unverified and receives nothing further until it is verified again.
• A delivery record for every report card and progress report: to whom, on which channel, when, and whether the carrier accepted it, delivered it, or it bounced.
• Guardian details are entered by the school, by the learner's class teacher, or by the learner in the portal. We do not source guardian contact details from anywhere else.

Everyone

• Technical. IP address, browser and device type, pages visited, and timestamps, held in server and security logs.
• Support. Anything you send us when you ask for help.

• To run the school's assessment cycle. Build papers, deliver them on paper or online, mark them, compute continuous assessment and term totals, and produce report cards in the grading system the school has chosen.
• To send report cards and progress reports. When a school releases term results, we send each learner's report card to the verified guardians on file by email and, where they have opted in, WhatsApp. On plans that include it, we also send a monthly progress report during term.
• To give learners the portal. Sit assessments online, revise with flashcards, quizzes and podcasts, play trivia, and, where the school has enabled the Student Tech Fee features, talk to the AI tutor and see a readiness score.
• To generate AI content. Draft assessment items and marking schemes from teacher-provided material, write the narrative summary in guardian reports, produce revision material, and answer learners' questions. See section 6 for exactly what is sent to AI providers.
• To keep accounts secure. Authenticate users, send one-time codes, detect unusual sign-ins, rate-limit abuse, and protect public forms from bots.
• To bill. Process plan payments and Student Tech Fees, apply coupons and balances, and settle school fees to the school.
• To support you. Answer questions, investigate problems, and tell you about incidents or material changes to the service.
• To improve Provsy. Understand which features are used and where they fail, using aggregated or de-identified data wherever possible.

We do not use personal data for advertising, we do not build profiles of learners for any purpose other than the reports the school has asked for, and we do not sell personal data to anyone.

Where Provsy processes personal data on a school's instructions, the school is responsible for having a lawful basis, which is normally the performance of its educational functions and its contract with the family. Schools should make sure their own privacy notices tell parents that Provsy is used and that report cards and progress reports may be delivered by email and WhatsApp.

Where Provsy is the controller, we rely on: performance of a contract (account, billing, support); our legitimate interests in keeping the service secure and understanding how it is used, balanced against your interests; legal obligation (tax and accounting records); and consent, for analytics cookies and for WhatsApp messaging.

WhatsApp specifically

We send nothing to an email address or WhatsApp number that the guardian has not confirmed with a one-time code delivered to it. For WhatsApp, the number must also have been entered with an explicit consent tick. Consent is recorded with a timestamp and can be withdrawn at any time by asking the school or by contacting us; from that moment the contact is no longer a delivery target. We do not use WhatsApp for marketing.

Provsy uses large language models to draft assessment items, diagrams and marking schemes, to summarise a learner's progress for a guardian report, to produce revision material and podcasts, and to power the AI tutor. We use enterprise AI services from Microsoft Azure and the other providers listed in section 7, under agreements that prohibit them from using your data to train their models.

What is sent depends on the task:

• Assessment generation. The teacher's uploaded or typed source material, the subject, level and curriculum. No learner data is involved.
• Guardian report summaries. The learner's first name, class level, school name, and the aggregated assessment, revision and engagement figures for the period, so the summary can refer to them specifically. Individual peers' scores are never included and the model is instructed never to disclose rankings.
• AI tutor and revision. The learner's question and the relevant subject material.

Under our agreements with these providers, data sent through their enterprise APIs is not used to train their models. We do not use your school's material or your learners' data to train models of our own.

AI output is a draft, not a decision

By default, every AI-generated paper goes through the school's approval before it is published to learners; a school may choose in its settings to publish without review, and that choice, and the review it forgoes, belongs to the school. Every figure in a guardian report is computed by Provsy's own arithmetic from the marks the school recorded; the model only writes the words around them. The AI tutor's answers can be wrong. Neither a readiness score nor a report narrative should be treated as the school's formal judgement of a child unless the school adopts it.

We share personal data with three kinds of recipient and no others.

Within the school

Teachers see the learners and subjects they are assigned; a class teacher also sees the profiles and guardian details of the learners in their own class. School administrators see everything in their school. Learners see their own results when the school releases them. Guardians receive reports about the learner they are linked to and nothing about anyone else. No school can see another school's data.

Our sub-processors

We use the following companies to run Provsy. Each is bound by contract to process data only on our instructions and to protect it.

• Microsoft Azure. AI services, storage and audio processing.
• Google. AI services; Google Analytics on the marketing website, only if you accept analytics cookies.
• Amazon Web Services. Storage, audio processing, and AWS End User Messaging Social, through which we send WhatsApp messages on the Meta WhatsApp Business Platform.
• Meta Platforms. WhatsApp Business Platform, for delivery of report cards, progress reports and verification codes to guardians who have opted in.
• Email delivery provider. Transactional email: verification codes, password resets, security alerts, report cards and guardian reports.
• Payment processor. Payment processing for plans and Student Tech Fees, and settlement of school fees to school settlement accounts. Card details are entered on the processor's secure checkout and never pass through Provsy.
• Cloudflare. Turnstile bot protection on our public forms and network security.
• Sentry. Error monitoring. We scrub names, email addresses and other identifiers from error reports before they leave our servers.
• Hosting and infrastructure providers. For our application servers, database, cache and PDF rendering.

We will update this list when a sub-processor changes. Schools that have signed data processing terms with us will be notified in advance and may object.

Legal requirements

We will disclose personal data where the law requires it, for example to the Nigeria Data Protection Commission, a court, or law enforcement acting under lawful authority. We validate every request, disclose the minimum necessary, and tell the affected school unless we are legally prevented from doing so.

We do not sell personal data, we do not share it with advertisers or data brokers, and we do not share learner data with anyone for a purpose other than the school's.

Our sub-processors operate data centres outside Nigeria, including in the European Union, the United Kingdom and the United States. Where personal data leaves Nigeria we rely on the transfer mechanisms permitted under the NDPA, including contractual clauses with the recipient and, for UK and EU schools, standard contractual clauses or the UK International Data Transfer Addendum. Details of the mechanism for a particular provider are available on request.

• Encryption. All traffic between your browser and Provsy is encrypted with TLS. Data at rest is encrypted by our hosting providers.
• Authentication. Passwords are stored only as salted hashes. Sign-in, password reset and guardian verification use time-limited one-time codes. New-device sign-ins trigger a security alert email.
• Access control. Every record is scoped to a school, and database rules enforce that a teacher, learner or guardian can only reach what their role permits. Provsy staff access is limited to what is needed to operate and support the service.
• Abuse protection. Public forms are protected against bots, and authentication and sensitive endpoints are rate-limited.
• Monitoring. Errors and security events are logged and reviewed. Identifiers are scrubbed from error reports.
• Incident response. If a breach is likely to affect you, we will notify the affected school without undue delay and within the time required by law (72 hours to the Nigeria Data Protection Commission under the NDPA), and give the school what it needs to inform its families.

No system is perfectly secure. If you believe an account has been compromised or you have found a vulnerability, please write to us immediately at [email protected].

A report card is a school record, and schools are expected to be able to reproduce one years after it was issued. Our retention reflects that.

• Assessment records, marks and report cards. Retained for as long as the school keeps its Provsy account, whether or not it has an active plan, because a school must be able to reproduce a report card years after issuing it. Deleted on the school's instruction, 90 days after the account is closed, or after 24 months with no active plan and no administrator sign-in, in which case we give the school 60 days' notice by email first.
• Learner and guardian details. Retained while the learner is on the school's roster; a school may deactivate or delete a learner whenever it wishes.
• AI tutor conversations and revision activity. Retained while the learner has portal access, and deleted with the learner record.
• Delivery records. Retained alongside the report they belong to, so the school can show what was sent, to whom, and when.
• Account and billing records. Retained for the life of the account and thereafter as required by Nigerian tax and company law, typically six years.
• Security and access logs. Retained for up to 12 months.
• Website enquiries. Retained for up to 24 months unless they lead to a customer relationship.
• Backups. Deleted data leaves backups on the next rotation cycle.

When a school closes its account or asks us to, we will provide an export of its data in a machine-readable form and then delete it, except where we are required to keep a record by law.

Under the NDPA, and the UK or EU GDPR where they apply, you have the right to access the personal data held about you, to have inaccuracies corrected, to have it erased, to restrict or object to its processing, to receive it in a portable form, to withdraw consent you have given, and to lodge a complaint with a supervisory authority.

How to exercise them depends on who holds the decision:

• Learners and guardians. Ask your school first. The school controls its roster and reports and can correct a name, change or remove a guardian contact, switch off WhatsApp delivery, or delete a record directly from its console. If you contact us instead, we will pass the request to the school and help it respond within the statutory period.
• Teachers. Update your own profile in the teacher workspace; for anything else, ask your school administrator or contact us.
• School administrators and website visitors. Contact us directly at [email protected]. We will respond within one month, or sooner where the law requires.

We will never charge for a rights request unless it is manifestly unfounded or excessive, and we will never penalise anyone for making one.

You may complain to the Nigeria Data Protection Commission (ndpc.gov.ng). If you are in the United Kingdom you may complain to the Information Commissioner's Office (ico.org.uk). We would appreciate the chance to resolve your concern first.

Most learners on Provsy are under 18 and many are under 13. Their data is placed on Provsy by their school in the course of its educational duties, and the school, not the learner, decides what is recorded. We design for this:

• A learner can only be on Provsy if their school put them there or gave them a school code to register with.
• We collect no more from a learner than the roster and the learning activity described above.
• We do not advertise to learners, and we do not use their data for any purpose the school has not asked for.
• Schools are responsible for providing any notice to, or obtaining any consent from, parents that their own law and policies require before enrolling a child on Provsy.

If you are a parent and believe your child's data is on Provsy without the school's authority, please contact us and we will investigate with the school immediately.

Provsy uses strictly necessary cookies to keep you signed in and to remember your cookie choice. These cannot be switched off without breaking the service.

On the marketing website we ask before loading Google Analytics. If you decline, no analytics script is loaded. Your choice is stored in a cookie on provsy.com so it is honoured across our subdomains. Inside the school console, teacher workspace and learner portal we do not run third-party advertising or analytics trackers.

You can withdraw analytics consent at any time by clearing your cookies for provsy.com, after which you will be asked again.

We will update this policy when the service or the law changes. The date and version at the top tell you when. For material changes affecting how school or learner data is processed, we will email school administrators before the change takes effect and give schools that have signed data processing terms the notice those terms require. Continued use of Provsy after the effective date means the updated policy applies.