Privacy Notice

1. Who we are and what this notice covers

This Privacy Notice is issued by Novaxion Systems LTD (“Novaxion”, “we”, “us” or “our”), a company registered in Nigeria (RC number to be inserted), with its registered office at [registered office address to be inserted].

It explains how personal data is handled in TermBook, an Android app teachers and schools use for score sheets, term results, report sheets, class registers and school sync. It also covers the services behind the app: our servers, email, support and Google Play subscriptions.

We process personal data in line with the Nigeria Data Protection Act 2023 (NDPA), administered by the Nigeria Data Protection Commission (NDPC).

2. Who is responsible for the data

• The school is the data controller for the records it keeps in TermBook about its pupils and classes: class lists, scores, results, comments and class registers. It decides what is recorded and who on its staff can see it.
• Novaxion is the data processor for those school records. We store and sync them on the school’s instructions and use them for nothing else.
• Novaxion is the data controller for your account (name, email, phone, password), for subscriptions, for support conversations, and for the records we keep to prevent misuse of free terms.

Questions about why your school records something, or about a pupil’s records, should go to the school first. We will help the school answer.

3. Personal mode: records on your phone

You can use TermBook on your own, without joining a school. Your classes, pupils and scores are then kept only on your phone, in an encrypted database. We do not receive them.

• A backup file you make is saved where you choose (for example your Google Drive or WhatsApp). It is not password-protected, so keep it somewhere safe.
• You can protect the app with a PIN or fingerprint (Settings → App lock).
• Uninstalling TermBook deletes these records from the phone.

4. Data we collect

5. Pupils' data

Schools record pupils’ names, admission numbers, sex, date of birth (optional), parent phone number (optional), classes, scores, results, teacher and principal comments, and attendance. Pupils do not use TermBook themselves.

• Each staff member sees only the classes and subjects their role gives them; the school admin sees the whole school.
• We do not use pupils’ data for anything other than providing TermBook to the school.
• Report sheets and other files a school prints or shares are the school’s responsibility once they leave the app.

6. Location

A school can choose to have class registers taken on its premises. If it does, TermBook reads your phone’s location once, at the moment you save a register, while the app is open. There is no background tracking and no location history.

• We store the distance from the school, whether it was inside the school area, the accuracy, and whether a fake-location app was detected.
• Only the school admin sees where a register was taken.
• Android asks your permission first. You can turn it off; the school may then mark registers for review.

7. Free terms and preventing abuse

Each school gets one free term. So that the same people can’t take free term after free term by opening new schools, we keep a record of who took part in each free term: the account and a scrambled code (hash) made from the email address with a secret key. The code can’t be turned back into the email. It lets us recognise the same mailbox if it is used again.

If a free term is refused or ended because of this, the school admin is told why, and can ask us to review it.

8. How we use data

• to provide TermBook: sign-in, school sync, report sheets and backups;
• to send emails you need: sign-up codes, password resets, staff invitations;
• to give access to plans bought through Google Play;
• to keep the service secure and prevent misuse of free terms;
• to answer support requests and fix problems.

Our legal bases under the NDPA are: performing our contract with you or your school; our legitimate interest in a secure service that is not misused; legal obligations (such as tax records); and your consent where we ask for it (such as location).

9. Sharing data

We share personal data only with:

• Your school: staff see school records as their role allows.
• Service providers who process data for us under contract: our hosting provider (servers and database), our email delivery provider, and Google for Google Play Billing.
• Authorities, when the law requires it.

We never sell personal data, and we do not use it for advertising.

10. When Novaxion staff see data

A small Novaxion team runs TermBook. They use a private console that shows schools’ plan status and counts, never pupils’ names, scores or attendance. Sign-in needs a password and a one-time code; staff emails are partly hidden; and every action is written to a tamper-evident log with its reason.

11. International data transfers

Some service providers, including Google, may process data outside Nigeria. When that happens we use the safeguards the NDPA requires, such as contractual protections.

12. How long we keep data

• School records are kept while the school uses TermBook. If its plan ends, they stay viewable and exportable (read-only); after 12 months without a plan, and after a warning by email, the school is archived. We never delete a school’s records without notice.
• Your account is kept until you delete it (section 15).
• Free-term codes are kept while TermBook offers free terms, because they exist to recognise repeat free terms.
• Purchase records are kept as long as tax and accounting law requires.
• Email codes expire after 10 minutes. Backups of our servers are overwritten on a rolling basis.

13. How we protect data

• Data travels between the app and our servers over encrypted (HTTPS) connections.
• Records on the phone are kept in an encrypted database; the app can be locked with a PIN.
• Passwords, email codes and sign-in tokens are stored only as hashes.
• Access depends on each person’s role, and changes to school records are recorded in an audit log.
• A school admin can remove a staff member, which ends their access at once.

No system is perfectly secure. If a breach affects your data, we will notify the school and the NDPC as the law requires and, where appropriate, you.

14. Your rights

Under the NDPA you can:

• ask what personal data we hold about you, and get a copy of it;
• have it corrected;
• ask for it to be deleted;
• restrict or object to its processing;
• move it to another service;
• withdraw your consent;
• ask for a person to review a decision, such as a refused free term.

For school records, including a pupil’s, the school decides on the request because it is the controller. Parents should contact the school; you can also contact us and we will pass the request on.

15. Deleting your account

In the app: Settings → Delete my account. Or from any browser, on novaxion.ng/accounts.

• Deleted: your name, email, phone number and password; you are signed out on every phone.
• Kept by your school: the school’s records you worked on (pupils, scores, attendance), because they belong to the school.
• Deleted with you: a school where you are the only member, with all its records.
• If you are the only admin of a school that has other staff, make another staff member an admin first, so the school can carry on.
• Kept by us: purchase records as tax law requires, and free-term codes (section 7), which can’t identify you on their own.

If you have a subscription, cancel it in Google Play first (Play Store → Payments and subscriptions); deleting your account does not cancel it.

16. Changes to this notice

We may update this notice. When we do, we will change the “Effective date” above, and for significant changes we will tell you in the app or by email before they take effect.

17. Contact us and complaints

• Privacy email: privacy@novaxion.ng
• Support email: support@novaxion.ng
• In the app: Settings → Help and support
• Registered office: [registered office address to be inserted]

If you are not satisfied with our response, you can complain to the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.