Privacy Policy

1. Introduction

Welcome to Playdules, an educational technology platform that combines learning, creativity, games and interactive experiences.

Playdules is a proprietary product and intellectual property of:

Noveldraw Creative
763, Abubakar Usman,
Jabi, Abuja, FCT, Nigeria.

In this Privacy Policy, “Playdules,” “we,” “us,” and “our” refer to Playdules and Noveldraw Creative in relation to the operation of the Playdules platform.

This Privacy Policy explains how we collect, use, store, protect and otherwise process personal data when you use:

• the Playdules website;
• Playdules web applications and services;
• Playdules accounts;
• Playdules games and learning activities;
• school, teacher and classroom features;
• authentication services, including sign-in through third-party services such as Google; and
• other services or features that link to this Privacy Policy.

We are committed to respecting the privacy and safety of all Playdules users, with particular care for children, students and other minors who may use the platform.

This Privacy Policy is intended to operate in accordance with the Nigeria Data Protection Act 2023 (NDPA), applicable regulations and directives issued by the Nigeria Data Protection Commission (NDPC), the Child Rights Act and other applicable Nigerian laws and regulations.

The NDPA requires personal data to be processed in a fair, lawful, transparent and secure manner and according to specified and legitimate purposes.

2. Who is responsible for your personal data?

For users who independently register for and use Playdules, Noveldraw Creative is responsible for the processing of personal data associated with the Playdules service, subject to applicable law.

Data Controller / Platform Operator:
Noveldraw Creative
763, Abubakar Usman,
Jabi, Abuja, FCT, Nigeria.

Privacy Contact: support@pladules.com

We recommend that users contact us through the above address for privacy questions, requests or concerns.

3. What personal data do we collect?

The information we collect depends on how you use Playdules. We aim to collect only information that is reasonably necessary for the relevant purpose.

3.1 Account Information

When you create a Playdules account, we may collect:

• name or display name;
• email address;
• username;
• password or authentication credentials where applicable;
• date of birth or age information where required for age-appropriate services;
• profile information;
• account type, such as student, teacher, parent or administrator; and
• other information you voluntarily provide.

3.2 Google or Third-Party Sign-In

If you choose to sign in using Google or another supported authentication provider, we may receive information made available to us by that provider, such as:

• your name;
• email address;
• profile identifier;
• profile image, where permitted; and
• authentication information necessary to establish your account.

We do not receive your Google password.

Your use of Google authentication is also subject to Google’s own privacy terms and policies. Playdules uses information received through authentication services only for legitimate purposes associated with account creation, authentication, security and operation of the service.

4. Information about children and minors

4.1 Our commitment to children

Playdules may be used by children and young people as part of educational, creative or recreational activities. We recognise that children require additional privacy protection.

Where Playdules processes personal data relating to a child, we will apply safeguards appropriate to the child’s age, the nature of the service and the risks associated with the processing. Under Nigeria’s current data-protection framework, the NDP Act’s child protections operate alongside the Child Rights Act, under which a child is generally treated as a person under 18. The NDPC has specifically highlighted parental/guardian consent, age and consent verification and additional safeguards for children’s personal data.

4.2 Parental or guardian consent

Where the law requires consent for processing a child’s personal data, Playdules will seek appropriate consent from the child’s parent or lawful guardian. Depending on the circumstances, this may include:

• obtaining parental or guardian consent before creating or activating an account;
• using an appropriate age-verification or consent mechanism;
• requiring a school or authorised educational institution to establish the appropriate authority to create student accounts;
• restricting certain features until the required consent or authorisation has been obtained; or
• taking other reasonable measures appropriate to the technology and circumstances.

Where processing is based on consent, consent may be withdrawn subject to applicable legal requirements and the practical consequences of withdrawal.

4.3 Information we do not intentionally seek from children

Playdules does not intentionally require children to provide unnecessary sensitive personal information. Unless specifically necessary for a legitimate educational, safety, legal or operational purpose, children should not be asked to provide information such as:

• home address;
• personal telephone number;
• government identification numbers;
• financial information;
• precise location;
• health information;
• biometric information; or
• other sensitive personal information.

Parents, guardians, teachers and schools should also avoid submitting unnecessary personal information about children.

4.4 Children’s public profiles and content

Playdules is designed to minimise unnecessary public exposure of children’s information. Where appropriate, children’s accounts may use usernames, nicknames, avatars, student identifiers or other non-identifying profile information rather than displaying a child’s full identity publicly. Children should not be encouraged to publish personal contact information, home addresses or other sensitive information through Playdules.

4.5 School and teacher accounts

Where a school, teacher or educational institution uses Playdules to create or manage student accounts, the school or institution is responsible for ensuring that it has the appropriate authority, notices and permissions required to provide student information to Playdules. Depending on the particular service and processing activity:

• the school may act as a data controller for student information it determines to process; and
• Playdules may act as a data processor on behalf of the school.

Playdules will process student information provided by schools for the purposes authorised by the applicable school arrangement and this Privacy Policy. Schools should not provide Playdules with more student information than is reasonably necessary for the educational service.

5. Educational and school data

Playdules may provide features for schools, teachers and educational organisations. These features may involve information such as:

• student names or display names;
• student identifiers;
• class or group membership;
• school affiliation;
• teacher information;
• learning activities;
• game participation;
• scores;
• progress;
• achievements;
• assignments;
• responses to learning activities;
• attendance or participation information where a school chooses to use such functionality; and
• teacher-created educational content.

Where a school provides student information to Playdules, we will use that information to provide, maintain, secure and improve the services authorised by the school and as otherwise permitted by law. We will not sell children’s educational records or student information.

6. Information generated through use of Playdules

When users interact with Playdules, we may collect information about their use of the service, including:

• games played;
• activities completed;
• scores;
• progress;
• achievements;
• learning interactions;
• pages or features accessed;
• session information;
• device type;
• browser type;
• operating system;
• approximate location derived from technical information where necessary;
• IP address;
• date and time of activity;
• error reports; and
• technical and diagnostic information.

We use this information to operate the service, maintain security, provide educational functionality, troubleshoot problems and understand how our platform is being used.

7. User-generated content

Users, teachers and schools may create or submit content to Playdules, including:

• games;
• questions;
• quizzes;
• educational activities;
• text;
• images;
• designs;
• responses;
• lesson materials;
• feedback; and
• other creative or educational content.

Users should not submit personal information about themselves or another person unless it is necessary and appropriate for the relevant activity. Where content is created by a child, we will apply appropriate safeguards to the extent required by applicable law.

8. Artificial intelligence and automated features

Some Playdules features may use artificial intelligence or automated technologies to assist users in creating games, educational activities, content or other experiences. Where such technologies are used, Playdules will take reasonable steps to ensure that personal data is not unnecessarily submitted to or processed by such systems.

We may use AI or automated technologies to:

• generate or assist with educational content;
• generate game concepts or activities;
• assist teachers or creators;
• improve platform functionality;
• detect misuse or security issues; or
• provide other features described within the platform.

Playdules will not knowingly use children’s personal data to train publicly available artificial intelligence models without an appropriate lawful basis and safeguards required by applicable law. Where third-party AI providers are used, relevant data may be processed by those providers only as necessary for the applicable service and subject to appropriate contractual, security and privacy safeguards.

9. Why do we process personal data?

We may process personal data for the following purposes:

A. Providing the Playdules service

Including:

• creating accounts;
• authenticating users;
• providing games and educational experiences;
• managing classes;
• providing teacher and school features;
• recording learning progress;
• maintaining user profiles; and
• delivering requested services.

B. Security

Including:

• preventing fraud;
• preventing abuse;
• detecting unauthorised access;
• protecting users;
• maintaining platform security; and
• investigating security incidents.

C. Service improvement

We may use appropriate information to:

• understand platform usage;
• diagnose technical problems;
• improve functionality;
• improve user experience;
• develop new educational features; and
• evaluate platform performance.

Where possible, we will use aggregated, anonymised or de-identified information for analytics and product improvement.

D. Communication

We may use contact information to:

• respond to support requests;
• provide important service notices;
• communicate account-related information;
• provide security notifications; and
• send other communications where legally permitted.

We will not use children’s personal data for direct marketing in circumstances prohibited by applicable law.

E. Legal compliance

We may process personal data where necessary to:

• comply with legal obligations;
• respond to lawful requests;
• protect our legal rights;
• investigate suspected unlawful activity; or
• fulfil other responsibilities imposed by law.

10. Our lawful bases for processing

Depending on the circumstances, Playdules may process personal data based on one or more lawful bases recognised under Nigerian data-protection law, including:

• consent;
• performance of a contract or provision of a requested service;
• compliance with a legal obligation;
• protection of vital interests;
• performance of a task carried out in the public interest where applicable; and
• legitimate interests, where permitted by law and where those interests do not override the rights and freedoms of the data subject.

Where consent is required, we will seek consent in an appropriate and understandable manner. The NDPC identifies consent, legal obligation and other recognised lawful bases as foundations for lawful processing under Nigeria’s data-protection framework.

11. Data minimisation

We seek to collect and process only personal data that is adequate, relevant and reasonably necessary for the purpose for which it is being processed. We do not intend to collect personal information simply because it may be useful in the future. This is particularly important when dealing with children and students.

12. How we share personal data

We do not sell personal data. We may share personal data only where reasonably necessary for the operation of Playdules or where permitted or required by law. This may include sharing information with:

Service providers

We may use trusted third-party providers for services such as:

• cloud hosting;
• database infrastructure;
• authentication;
• email delivery;
• analytics;
• security;
• technical support;
• payment processing;
• artificial intelligence services; and
• other technology infrastructure.

Such providers may process personal data only as necessary to provide their services to us and subject to appropriate contractual and security arrangements.

Schools and teachers

Where a user participates in a school or classroom environment, relevant information may be made available to authorised teachers, school administrators or other authorised educational personnel. For example, a teacher may be able to see student participation, scores or learning progress where the relevant Playdules functionality permits it.

Parents or guardians

Where appropriate and legally permitted, parents or guardians may receive information relating to a child’s account or use of Playdules.

Legal and regulatory authorities

We may disclose personal data where required or authorised by applicable law, court order, regulatory requirement or lawful government request.

13. International data transfers

Some technology providers used by Playdules may process information outside Nigeria. Where personal data is transferred outside Nigeria, Playdules will take reasonable steps to ensure that the transfer and subsequent processing comply with applicable Nigerian data-protection requirements, including requirements relating to international transfers. Where required, appropriate safeguards, contractual protections or consent mechanisms will be used. The NDPC’s current framework specifically addresses international transfers and requires appropriate safeguards in applicable circumstances.

14. Data security

We take reasonable technical and organisational measures to protect personal data against:

• unauthorised access;
• accidental loss;
• unlawful processing;
• alteration;
• disclosure;
• destruction; and
• other forms of misuse.

Security measures may include:

• access controls;
• authentication controls;
• encryption where appropriate;
• secure development practices;
• monitoring;
• backups;
• restricted administrative access; and
• security incident procedures.

No internet-based service can guarantee absolute security. However, we continuously work to reduce privacy and security risks.

15. Data retention

We retain personal data only for as long as reasonably necessary for:

• the purpose for which it was collected;
• providing the requested service;
• legitimate business and operational purposes;
• fulfilling legal or regulatory obligations;
• resolving disputes; or
• enforcing agreements.

When personal data is no longer required, we will take reasonable steps to delete, anonymise or securely dispose of it. School-related student information may be retained according to the applicable school relationship, contractual requirements and legal obligations.

16. Your data protection rights

Subject to applicable law and any lawful limitations, data subjects may have rights including:

• the right to be informed about processing;
• the right to request access to personal data;
• the right to request correction of inaccurate or incomplete information;
• the right to request deletion or erasure where applicable;
• the right to withdraw consent where processing is based on consent;
• the right to object to certain processing;
• the right to request restriction of processing in applicable circumstances;
• the right to data portability where applicable;
• the right to object to certain automated decision-making; and
• the right to lodge a complaint with the relevant data-protection authority.

The NDPC itself identifies rights including erasure, withdrawal of consent, portability, objection and rectification among the rights available to data subjects.

17. Children’s data rights

Parents and lawful guardians may contact us regarding personal data belonging to a child under their responsibility. Depending on the circumstances and applicable law, a parent or guardian may request:

• access to the child’s personal data;
• correction of inaccurate information;
• deletion of information;
• withdrawal of consent;
• information about how the child’s information is being used; or
• other rights available under applicable data-protection law.

We may take reasonable steps to verify the identity and authority of a person making such a request before disclosing or changing personal data. This is necessary to prevent unauthorised persons from obtaining or altering children’s information.

18. How to request access, correction or deletion

A privacy request can be made by contacting:

Email: support@pladules.com

Please include:

• your name;
• the email address associated with the account, where applicable;
• the nature of your request; and
• sufficient information to help us identify the relevant account or information.

For requests relating to a child, we may require reasonable evidence that the requester is the child’s parent, guardian or otherwise authorised representative. We will respond to legitimate requests within the timeframe required by applicable law.

19. Cookies and similar technologies

Playdules may use cookies, local storage and similar technologies. These technologies may be used for:

• authentication;
• maintaining sessions;
• remembering preferences;
• security;
• functionality;
• performance;
• analytics; and
• improving the service.

Where consent is legally required, we will provide an appropriate mechanism for obtaining and managing consent. Users may also be able to control cookies through their browser settings, although disabling certain cookies may affect Playdules functionality. The NDPC’s current guidance recognises that cookies can involve the processing of personal data and addresses consent requirements for cookies in applicable circumstances.

20. Third-party services and links

Playdules may integrate with or link to third-party services. These may include authentication providers, educational tools, payment providers, analytics services, cloud infrastructure and other technology services. Third-party services operate under their own privacy policies and terms. We encourage users and parents/guardians to review the privacy practices of third-party services before using them.

21. Marketing

Playdules may communicate with users about its services, products, updates and educational activities where legally permitted. Where direct marketing requires consent, we will obtain the appropriate consent. Users may withdraw marketing consent or unsubscribe from promotional communications where applicable. We do not knowingly use children’s personal data for inappropriate behavioural advertising or direct marketing.

22. No sale of children’s data

Playdules does not sell children’s personal data. We also do not knowingly sell student educational records, school records or classroom performance information. Where information is shared with service providers, the sharing is for legitimate operational, educational, technical, security or legal purposes and not as a sale of personal data.

23. Data breaches and security incidents

If Playdules becomes aware of a personal-data breach, we will assess the incident and take reasonable steps to:

• contain the incident;
• investigate what happened;
• protect affected accounts and information;
• mitigate potential harm;
• comply with applicable notification requirements; and
• notify affected individuals or relevant authorities where required by law.

24. Privacy by design for children

Because Playdules may be used by children, we aim to incorporate privacy and safety considerations into the design of relevant features. Depending on the feature, this may include:

• limiting the amount of personal information collected;
• restricting public profile information;
• providing age-appropriate experiences;
• limiting unnecessary communication between users;
• implementing appropriate access controls;
• restricting access to student information to authorised users;
• using non-identifying student identifiers where appropriate;
• providing parental or school controls; and
• reviewing new features for privacy and child-safety risks.

25. Parents, guardians and schools

We encourage parents, guardians and schools to supervise children’s use of online services appropriate to their age. Schools using Playdules should:

• provide students with appropriate privacy information;
• obtain required permissions or consents;
• ensure that student information supplied to Playdules is accurate and necessary;
• maintain appropriate access controls;
• avoid providing unnecessary sensitive information; and
• notify Playdules where student information requires correction or deletion.

Playdules may provide schools with administrative tools to help manage student accounts and educational data.

26. Account deletion

Users may request deletion of their Playdules account by contacting us at support@pladules.com. When an account is deleted, we will take reasonable steps to delete or anonymise associated personal data, subject to information that we are legally required or permitted to retain. Certain information may remain in backups for a limited period before being securely overwritten in accordance with our retention and backup procedures.

27. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When significant changes are made, we may provide appropriate notice through:

• the Playdules website;
• the Playdules application;
• email;
• an account notification; or
• another appropriate communication method.

The “Last Updated” date at the beginning of this Privacy Policy will indicate when it was most recently revised.

28. Governing law

This Privacy Policy shall be interpreted in accordance with the laws of the Federal Republic of Nigeria, including applicable provisions of:

• the Nigeria Data Protection Act 2023;
• applicable regulations, directives and guidance issued by the Nigeria Data Protection Commission;
• the Child Rights Act;
• the Constitution of the Federal Republic of Nigeria; and
• other applicable Nigerian laws and regulations.

The NDPC states that the NDP Act applies to organisations domiciled, resident or operating in Nigeria and to certain processing of personal data relating to individuals in Nigeria.

29. Contact us

If you have questions about this Privacy Policy, wish to exercise a data-protection right, have a concern about the handling of a child’s information, or wish to report a privacy issue, please contact:

Noveldraw Creative
Proprietor of Playdules

Address:
763, Abubakar Usman,
Jabi, Abuja,
FCT, Nigeria.

Privacy & Support Email: support@pladules.com

30. Important notice for parents and guardians

If your child uses Playdules, we encourage you to talk with your child about online privacy and responsible use of personal information. Children should not be encouraged to disclose information such as their home address, private telephone number, passwords, financial information or other sensitive personal information through Playdules or any other online service.

If you believe that your child’s personal information has been collected or used improperly, please contact us immediately at support@pladules.com. We will investigate the matter and take appropriate action in accordance with applicable law.