Privacy policy of Xtan

1. Introduction

This Privacy Policy regulates how Xtan Ltd (“Xtan”, “we”, “us”, or “our”) processes the personal information of our data subjects, including students, workers, trainees, and institutional members.

In line with the provisions of the Nigeria Data Protection Act (NDP Act), 2023, and other applicable laws, Xtan Ltd maintains strict privacy principles governing the collection, storage, and management of your personal data.

2. Our Guiding Principles

In processing your personal data, we adhere to the principles of fairness, lawfulness, and transparency.

Data is collected for specified, explicit, and legitimate purposes and is not further processed in a way incompatible with those purposes.

We ensure data is adequate, relevant, and limited to the minimum necessary for attendance verification.

3. Data Collection and Usage

We collect personal data to provide our services based on your level of engagement. The major types of personal data and purposes include:

S/N | PURPOSE OF COLLECTION | TYPE OF DATA | LAWFUL BASIS

1. Regulatory Actions | Name, Phone, Email, Contact Address, Sex, DOB, Photograph | Legal obligation / public interest

2. Notifications | Name, Phone, Email, Contact Address, Sex, DOB | Legal obligation / consent

3. Data Analytics | Name, Phone, Email, Contact Address, Sex, DOB | Consent / legitimate interest / legal obligation

4. Security | Name, Phone, Email, Contact Address, Sex, DOB, Photograph | Legal obligation / legitimate interest / public interest

5. Employment | Name, Phone, Email, Contact Address, Sex, DOB, Photograph, Medical Record, Educational Record | Contract / consent / vital interest / legal obligation

6. Contract | Name, Phone, Email, Contact Address, Sex | Contract

4. Location Data

The location feature is used to collect data to verify your physical presence during attendance windows.

By using Xtan, you provide explicit consent for the collection and processing of this location data.

5. Data Sharing and Disclosure

We respect the confidentiality of your information and only share it with:

• The specific institution with which you have a verified relationship.

• The relevant Federal or State Ministry of Education for statutory reporting.

We do not sell your data to third-party advertisers or disclose it to external entities without lawful justification.

Your rights include:

• Right to be informed

• Right of access

• Right to rectification

• Right to object to processing

• Right to data portability

• Right to be forgotten

• Right in relation to automated decision making

• Right to lodge a complaint with the Commission

6. Transfer of Data to Third Parties

Third parties may provide essential services through our platforms. Data shared is limited to contact details unless consent is provided.

Third-party services may include:

• Internet connectivity

• Marketing team

• Cloud storage

• Data analytics

• Data security

• Software development

All transfers comply with the NDP Act (Nigeria).

7. Data Protection Support Unit (DPSU)

Xtan Ltd has established a DPSU and appointed a Data Protection Officer (DPO) responsible for compliance and responding to privacy requests.

Internal mechanisms include:

• Data protection audits and impact assessments

• Breach remediation planning

• Data privacy advisory services

Concerns can be reported to fdoyebadeesq@gmail.com; redress will be within 7 working days.

8. Alteration of Policy

Xtan Ltd reserves the right to alter this policy to advance data privacy rights, protect public interest, or comply with lawful government directives under the NDP Act and Nigerian Constitution.

9. Confidentiality

Confidential Information includes business and technical information, whether received, accessed, or viewed in any form.

Exclusions include:

• Publicly available information

• Legitimately obtained from third parties

• Required by court order or law

All parties must protect confidential information and prevent unauthorized use or distribution.

10. Intellectual Property

Xtan Ltd and all logos, products, services, or content are intellectual property of Xtan Ltd or its licensors.

No copying, imitation, or use is allowed without prior written permission.

Use of Xtan does not transfer ownership or rights to users.

11. Cookie Policy

We use cookies for:

• Authentication and security

• Preference settings

• Session management

• Data integrity and fraud prevention

Types of cookies:

• Essential: necessary for platform function

• Functional: enhance user preferences and experience

Third-party cookies are only used for integrated institutional services or payment verification.

Disabling essential cookies may prevent logging in or using attendance features.

12. Legal Compliance, Notices & Amendments

You must comply with Nigerian laws when using our Services.

Notices can be provided electronically and are effective 30 days after posting.

We may amend this Agreement; amendments are effective 30 days after posting on https://Xtan.com/

13. Dispute Resolution

Disputes shall first attempt amicable resolution within 15 days.

Unresolved disputes are referred to arbitration per Arbitration and Mediation Act, 2023, under Lagos State Multi-Door Courthouse law.

Mediation decisions are binding; court action may be sought for enforcement or injunctive relief.

14. Extended Non-Use

Non-use of the platform does not terminate the agreement. Any dues remain payable upon reactivation.

15. General Provisions

Invalid or unenforceable provisions are severed; remaining provisions remain valid.

Rights and obligations may be assigned by Xtan Ltd.

Failure to enforce does not waive Xtan's rights.

Parties act as independent contractors responsible for their own obligations.

16. Force Majeure

Xtan Ltd is not responsible for delays caused by events beyond reasonable control, including acts of God, technical failures, strikes, natural disasters, pandemics, or government actions.