Privacy policy.

1. Information we collect

Depending on how you interact with Attention Factory, we may collect:

1.1 Identity and Contact Information

This may include:

• Name;
• Email address;
• Telephone number;
• Organisation or employer;
• Job title or professional role;
• Business address; and
• Other contact information you voluntarily provide.

1.2 Account and Registration Information

Where applicable, we may collect:

• Username;
• Account information;
• Program registration information;
• Course participation information;
• Attendance records;
• Certification or completion information; and
• Other information necessary to administer our Services.

1.3 Training and Program Information

When you participate in our Services, we may collect information relating to:

• Training attendance;
• Workshop participation;
• Questions and responses;
• Assignments and exercises;
• Feedback;
• Assessments;
• Learning progress;
• Programme preferences; and
• Other information voluntarily provided during participation.

1.4 Client and Business Information

Where we provide Services to an organisation, we may process information relating to:

• Business processes;
• Organisational structures;
• Workflows;
• Business objectives;
• AI adoption requirements;
• Operational challenges;
• Internal systems;
• Productivity and performance information; and
• Other information necessary to provide the agreed Services.

1.5 AI Inputs and Materials

Depending on the Services provided, you may voluntarily submit:

• Prompts;
• Questions;
• Documents;
• Files;
• Text;
• Data;
• Images;
• Business information;
• Workflow information; and
• Other materials for use in AI training, demonstrations, consulting, or implementation activities.

Users should not submit sensitive or confidential information to third-party AI systems unless they have confirmed that such use is appropriate and authorised.

2. How we use Personal Data

Attention Factory may use Personal Data to:

• Provide and administer our Services;
• Register participants for program;
• Deliver AI training and education;
• Provide consulting, advisory, and AI enablement Services;
• Communicate with users and clients;
• Manage events and workshops;
• Process payments;
• Monitor program participation;
• Improve our Services;
• Develop educational resources;
• Understand how users interact with our Services;
• Maintain security;
• Detect fraud, abuse, or unauthorised activity;
• Respond to enquiries and requests;
• Conduct research and analysis;
• Comply with applicable laws and regulations; and
• Protect the rights, property, and safety of Attention Factory, our users, clients, and third parties.

3. AI training and user data

Because Attention Factory provides AI education and enablement Services, participants may interact with AI systems during training, workshops, consultations, or other engagements.

Where AI tools are used, information submitted to those tools may be processed by the relevant third-party provider in accordance with that provider's terms and privacy policy.

Attention Factory does not control the privacy practices of third-party AI providers.

Before submitting Personal Data, confidential information, proprietary business information, or other sensitive information to a third-party AI tool, you should review the relevant provider's terms and privacy practices and ensure that you have the appropriate authority to submit such information.

4. Legal basis for processing

Where applicable, Attention Factory processes Personal Data on one or more lawful bases recognised under applicable data protection laws, including:

• Performance of a contract;
• Compliance with legal obligations;
• Consent;
• Legitimate interests; and
• Other lawful bases permitted under applicable law.

Where consent is required, we will obtain it before processing Personal Data.

5. Sharing of Personal Data

Attention Factory may share Personal Data where reasonably necessary with:

• Employees and authorised personnel;
• Trainers, instructors, facilitators, and consultants;
• Technology and infrastructure providers;
• Website and hosting providers;
• Payment processors;
• Communications providers;
• Analytics providers;
• Event and program partners;
• Professional advisers;
• Contractors and service providers;
• Affiliates, where applicable; and
• Government authorities, regulators, law enforcement agencies, courts, or other persons where required or permitted by law.

We may also disclose Personal Data in connection with a merger, acquisition, financing, restructuring, sale of assets, reorganisation, or other corporate transaction involving Attention Factory.

We will seek to ensure that third parties receiving Personal Data process it in accordance with applicable legal and contractual requirements.

6. International data transfers

Attention Factory may use service providers located in Nigeria, the United States, or other jurisdictions.

As a result, Personal Data may be transferred to or processed in jurisdictions outside the country in which you reside.

Where required by applicable law, Attention Factory will implement appropriate safeguards for international transfers of Personal Data.

7. Data retention

We retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected, including to:

• Provide Services;
• Maintain business and transaction records;
• Meet legal and regulatory requirements;
• Resolve disputes;
• Enforce agreements; and
• Protect our legitimate interests.

Retention periods may vary depending on the type and nature of the information.

8. Data security

Attention Factory is committed to protecting the privacy, security, and confidentiality of Personal Data.

We implement reasonable technical, administrative, physical, and organisational safeguards designed to protect Personal Data against:

• Unauthorised access;
• Unauthorised disclosure;
• Loss;
• Destruction;
• Alteration;
• Misuse; and
• Other unlawful processing.

Security measures may include access controls, confidentiality obligations, secure storage, encryption where appropriate, network security measures, and other reasonable security practices.

However, no method of transmission over the internet or electronic storage system can be guaranteed to be completely secure.

9. Your privacy rights

Subject to applicable law, you may have rights to:

• Request access to your Personal Data;
• Request correction of inaccurate information;
• Request deletion of Personal Data;
• Request restriction of processing;
• Object to certain processing activities;
• Request portability of Personal Data where applicable;
• Withdraw consent where processing is based on consent; and
• Lodge a complaint with the relevant data protection authority.

Requests may be submitted using the contact information provided below.

10. Cookies and analytics

Our website and digital Services may use cookies, analytics tools, and similar technologies to:

• Maintain website functionality;
• Understand website usage;
• Improve user experience;
• Analyse traffic and engagement; and
• Support security and performance.

Where required by applicable law, we will obtain appropriate consent for the use of non-essential cookies and similar technologies.

11. Children's privacy

Our Services are generally intended for adults and professional users.

We do not knowingly collect Personal Data from children in circumstances where such collection is prohibited by applicable law.

Where a program is specifically designed for younger participants, appropriate safeguards and consent requirements will apply.

12. Marketing and communications

Where permitted by applicable law, Attention Factory may send communications relating to:

• Program;
• Training opportunities;
• Workshops;
• Events;
• Educational resources;
• New Services; and
• Other relevant business or educational information.

Where required, you may opt out of marketing communications by following the unsubscribe instructions in the relevant communication or contacting us directly.

You may continue to receive essential administrative or transactional communications where necessary.

13. Photographs, recordings, and testimonials

Attention Factory may photograph or record certain events, workshops, training sessions, or programs for administrative, educational, archival, or promotional purposes.

Where required by applicable law, we will obtain appropriate consent before using identifiable photographs, recordings, or testimonials for promotional purposes.

Participants may contact us where they have concerns regarding the use of their image or recording.

14. Third-party websites and services

Our website or Services may contain links to third-party websites, applications, or platforms.

Attention Factory is not responsible for the privacy practices, security, content, or policies of third-party services.

We encourage users to review the privacy policies of third-party platforms before providing them with Personal Data.

15. Business transactions

If Attention Factory is involved in a merger, acquisition, financing, restructuring, reorganisation, sale of assets, or similar transaction, Personal Data may be transferred as part of that transaction where permitted by applicable law.

Where required, appropriate safeguards and notices will be provided.

16. Data breaches and security incidents

If Attention Factory becomes aware of a Personal Data breach or security incident affecting Personal Data, we will take reasonable steps to investigate, contain, mitigate, and remediate the incident.

Where required by applicable law, we will notify affected individuals and/or relevant regulatory authorities within the applicable timeframe.

If you become aware of a suspected security vulnerability or unauthorised access relating to our Services, please notify us promptly.

17. Changes to this Privacy Policy

Attention Factory may update this Privacy Policy from time to time.

Where material changes are made, we may notify users by updating the effective date, publishing the revised Privacy Policy, or providing other appropriate notice where required by law.

You should review this Privacy Policy periodically to remain informed about how we process Personal Data.

18. Governing law

This Privacy Policy shall be governed by the applicable laws of the Federal Republic of Nigeria, including applicable Nigerian data protection and privacy legislation.

Where mandatory data protection laws provide additional rights or protections, those rights shall apply notwithstanding anything inconsistent in this Privacy Policy.

19. Contact us

For questions, requests, complaints, or concerns regarding this Privacy Policy or the processing of your Personal Data, please contact:

Attention Factory — hello@attentionfactory.io