This Privacy Policy was last updated on 22 June 2023.

At Thrive Resource Centre, we are committed to protecting the privacy of our users and endeavor to protect the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you interact with our website and use our services.

By accessing or using Thrive Resource Centre, you agree to the terms of this Privacy Policy. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at Hello@thriveresoucecentre.com. Your use of our Site and/or services is also governed by our Terms of Use. Terms used but not defined in this Privacy Policy can be found in our Terms of Use

Table of Contents         

1.    What Information this Privacy Notice Covers

2.    What You Agree to by Using Our Site

3.    What Information We Collect

4.    How We Use the Information

5.    External Links

6.    Retention of Personally Identifiable Information

7.    Confidentiality & Security of Personally Identifiable Information

8.    Updating or Deleting Your Personally Identifiable Information

9.    Modifications to this Privacy Policy

10. Interpretation

11. Our Policy concerning Children

12. Questions, Suggestions and Complaints

1.    What Information this Privacy Policy Covers

This Privacy Policy covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any Personal Data, but for features or Services related to the Content Offerings, Personal Data is required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect, "Personal Data" (i.e., information that can be used to identify you and which may also be referred to as “personally identifiable information” or “personal information”). Personal Data can include information such as your name, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personal Data you submit to THRIVE. Inaccurate information may affect your ability to use our services, the information you receive while using our services, and our ability to contact you.

2.    What You Agree to by Using Our Site

We consider that the legal bases for using your personal information as set out in this Privacy Policy are as follows:

a.    our use of your personal information is necessary to perform our obligations under any dealings with you (for example, to comply with the Terms of Use of our Site which you accept by browsing our website and/or to comply with our contract to provide Services to you, your academic institution, your employer, or other organization that may be providing you with access to our Services); or

b.    our use of your personal information is necessary for complying with our legal obligations; or

c.     use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:

Ø run, grow and develop our business;

Ø operate our Site and provide our Services;

Ø select appropriately skilled and qualified suppliers;

Ø build relationships with partners and academic institutions;

Ø carry out research and statistical analysis;

Ø carry out marketing and business development; and

Ø for internal administrative and auditing purposes.

d.    consent, to send you certain communications or where you submit certain information to us, or where required to rely upon consent by local law.

Which legal basis applies to a specific activity will depend on the type of personal information used and the context in which it is being used.

If we rely on our (or another party’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent and we will stop doing so. If you withdraw your consent, this may impact the ability for us to provide some of our Services to you.

3.    What Information We Collect

We gather the following types of information about users through the Site:

3.1.                 Information relating to your use of our Site: When users come to our Site, we may track, collect, and aggregate information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system, and browser software used by each user of the Site. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of their point of connectivity. Location data may be used to route your traffic to the nearest regional server to reduce latency and improve your experience.

3.2.                 Personal Data provided directly by you or via third parties: We collect Personal Data that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our Site. We may use the Personal Data that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other THRIVE events, and send you email messages about Site maintenance or updates.

3.3.                 Account Registration: If you register for an account on our Site, you may be required to provide us with certain Personal Data such as your name and email address. You may also voluntarily provide us with additional Personal Data.

3.4.                 Updates: THRIVE may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these Services, you may be required to provide us with Personal Data such as your name and email address.

3.5.                 Participation in Content Offerings: THRIVE offers users the opportunity to participate in Content Offerings on or through the Site. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.

If you participate in a Content Offering, we may collect certain user-generated content, such as assignments you submit, peer-graded assignments, and peer grading feedback. We also collect course data, such as responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate in or submit such assignments, exams, or surveys.

3.6.                 Identity Verification: THRIVE may offer you the ability to verify your identity for select Services. In order to enroll for these Services, you may be required to provide us or our third-party identity verification vendor with Personal Data such as your name, address, date of birth, a headshot taken using a webcam, and a photo identification document.

3.7.                 Communications with THRIVE: We may receive Personal Data when you send us an email message or otherwise contact us.

3.8.                 Third Party Sites: We may receive Personal Data when you access or log-in to a third party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personal Data available from the third party site.

3.9.                 Surveys: We may receive Personal Data when you provide information in response to a survey operated by us or a Content Provider.

3.10.             Partner sites: Partner sites providing Content Offering-related tools and services to THRIVE users may collect nonfinancial individual-level user data regarding the individual’s use of that partner site while the partner sites provide those services to THRIVE. The partner sites may share that data with THRIVE for the purpose of improving our Services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.

3.11.             Third Party Payment Processing: THRIVE provides you with the ability to pay for Content Offerings and other Services using a credit card or other methods through a third party payment processing service provider. Please note that our service provider – not THRIVE – collects and processes your financial information.

4.    How We Use the Information

4.1.                 Information relating to your use of our Site: We use information relating to your use of the Site to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our Services and the Site.

4.2.                 Personally Identifiable Information provided directly by you or via third parties: Except as set forth in this Privacy Policy or as specifically agreed to by you, THRIVE will not disclose any of your Personal Data. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personal Data as described below.

4.3.                 Providing the Site and our Services: We use Personal Data which you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or Services that you request from us.

4.4.                 Technical support and security: We may use Personal Data to provide technical support to you, where required, and to ensure the security of our Services and the Site.

4.5.                 Updates: We use Personal Data collected when you sign-up for our various email or update services to send you the messages in connection with the Site or Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.

4.6.                 Participation in Content Offerings: We use the Personal Data that we collect from you when you participate in a Content Offering through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of the Content Offerings. We may also share your Personal Data and your performance in a given Content Offering with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.

4.7.                 Identity Verification: For Services that require identity verification, we may use the Personal Data that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. This service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after successful verification of your profile information.

4.8.                 Communications with or from THRIVE: When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.

4.9.                 Communications with THRIVE’s Business Partners. We may share your Personal Data with Content Providers and other business partners of THRIVE so that Content Providers and other business partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.

4.10.             Research: We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our Content Providers and other business partners so that our Content Providers and other business partners may use the data for research related to online education.

4.11.             Disclosure to THRIVE’s Operations and Maintenance Contractors: We use various service providers, vendors, and contractors (collectively, "Contractors") to assist us in providing our Services to you. Our Contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Content Offerings. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.

4.12.             Government Authorities; Legal Rights and Actions: THRIVE may share your Personal Data with various government authorities in response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personal Data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of THRIVE, the Site, our users, customers, or others; and in connection with our Terms of Use and other agreements.

4.13.             Disclosure to Acquirers: THRIVE may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of THRIVE to which your Personal Data relates.

4.14.             e-Readers: If we receive any Personal Data related to the extent to which you use designated e-Readers or other devices to access THRIVE materials, we may archive it, and use it for research, business, or other purposes.

5.    External Links

For your convenience we may provide links to sites operated by organizations other than THRIVE ("Third Party Sites") that we believe may be of interest to you. We do not disclose your Personal Data to these Third Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third Party Sites. If you choose to click on a link to one of these Third Party Sites, you should review the privacy policy posted on the other site to understand how that Third Party Site collects and uses your Personal Data.

6.    Retention of Personally Identifiable Information

We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data is collected and processed. The length of time we retain Personal Data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.

7.    Confidentiality & Security of Personally Identifiable Information

We will use industry standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Notice, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personal Data, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mail communications are typically not encrypted and should not be considered secure.

8.    Updating or Deleting Your Personal Data

You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by sending an email to Hello@thriveresourcecentre.com.

We try to answer every request promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that when deleting your Personal Data there may be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if we need to retain your Personal Data to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.

8.1.                 The Nigerian Data Protection Regulation 2019

Under the Nigerian Data Protection Regulation (“NDPR”) 2019, Nigerians have the right to know what personal information about them is collected, request deletion of their personal data, opt-out of the sale of their personal data, and not be discriminated against if they choose to exercise any of these rights. THRIVE does not sell any of the data we collect about you.

9.     Modifications to This Privacy Policy

From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Services, or as required by applicable law. We will also include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.

As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.

10.  Interpretation

Any capitalized terms not defined in this policy are defined as specified in THRIVE’s Terms of Use. Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, the English language version will take control.

11. Our Policy Concerning Children

We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Individuals younger than 18 years of age, but of the required age for consent to use online services where they live (for example, 13 in the US or 16 in Ireland), may not set up an account, but may have a parent or guardian open an account and help them access appropriate content. Individuals younger than the required age for consent to use online services may not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.

Parents who believe that THRIVE may have collected personal data from a child under those ages can submit a request that it be removed to Hello@thriveresourcecentre.com.

12. Questions, Suggestions and Complaints

If you have any questions, concerns, suggestions, complaints or disputes regarding our Privacy Policy, please feel free to contact our email at Hello@thriveresourcecentre.com.